Robert and Marie Banat - Page 1

                                   109 T.C. No. 3                                     

                               UNITED STATES TAX COURT                                

                       ROBERT AND MARIE BANAT, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2237-97.                    Filed August 5, 1997.           

                    H submitted requests for abatement of interest to                 
               the Internal Revenue Service prior to July 30, 1996,                   
               the date of enactment of sec. 6404(g), I.R.C.  After                   
               July 30, 1996, R sent to H a notice of final                           
               disallowance of abatement of interest pursuant to                      
               sec. 6404(g).  H and W filed a petition for review of                  
               the failure to abate interest.  R filed a motion to                    
               dismiss for lack of jurisdiction as to H on the ground                 
               that the request for abatement of interest was                         
               submitted prior to the effective date of sec. 6404(g)                  
               and as to W on the ground that no notice of final                      
               disallowance of abatement of interest was mailed to                    
                    Held:  We have jurisdiction to review the denial                  
               of H's request for abatement of interest, but we lack                  
               jurisdiction as to W.                                                  

               Robert and Marie Banat, pro se.                                        

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