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
her.
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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