Robert and Marie Banat - Page 2

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               Thomas J. Kerrigan, for respondent.                                    

               COHEN, Chief Judge:  This case is before us on respondent's            
          Motion to Dismiss for Lack of Jurisdiction.  The issue is whether           
          the Court has jurisdiction pursuant to section 6404(g) to                   
          consider petitioners' claims seeking abatement of interest.                 
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect at the time the petition was                
          filed, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.  The resolution of this issue turns on              
          the effective date of section 6404(g).                                      
               Petitioners are husband and wife who resided in Brooklyn,              
          New York, at the time the petition was filed.                               
               On August 13, 1995, petitioner Robert Banat submitted                  
          requests for abatement of interest to the Internal Revenue                  
          Service (IRS) pursuant to section 6404(e) for the taxable years             
          1985 through 1987.  The requests were submitted on Forms 843,               
          Claims for Refund and Request for Abatement, and were signed by             
          petitioner Robert Banat only.  All requests were disallowed by              
          the IRS Associate Chief, New York City Appeals Office, by                   
          issuance of a Notice of Disallowance (Notice) dated November 8,             
          1996.  The Notice is addressed to petitioner Robert Banat only              
          and states as follows:                                                      

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