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As provided by TBOR 2 section 302, our jurisdiction applies
to requests for abatement of interest after July 30, 1996.
According to respondent, TBOR 2 section 302 precludes judicial
review of all requests for abatement of interest submitted to the
IRS prior to July 31, 1996. With respect to requests made and
denied prior to July 31, 1996, we agree. See White v.
Commissioner, 109 T.C. ___ (Aug. 5, 1997).
We decline, however, to interpret the effective date
provision to preclude jurisdiction with respect to requests for
abatement of interest pending with the IRS on July 31, 1996.
TBOR 2 is intended by the Congress "to provide for increased
protections of taxpayer rights in complying with the Internal
Revenue Code and in dealing with the Internal Revenue Service
(IRS) in its administration of the tax laws." H. Rept. 104-506,
at 22 (1996). It would be inconsistent with that intent to
interpret the effective date language in a manner that would deny
judicial review to taxpayers whose requests are continuing,
considered, and denied after the date of enactment. In our view,
the denial of a request that is pending with the IRS after July
30, 1996, may be the subject of review under section 6404(g).
In this case, petitioner Robert Banat's requests for
abatement of interest were pending on July 31, 1996, and denied
on November 8, 1996. Respondent issued a "Notice of
Disallowance" that constituted a final determination not to abate
interest pursuant to section 6404(e), and a timely petition was
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