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filed. Accordingly, we hold that we have jurisdiction to review
respondent's denial of petitioner Robert Banat's requests for
abatement of interest. Sec. 6404(g); Rule 280(b)(2).
With respect to petitioner Marie Banat, no request for
abatement of interest was ever made to the IRS and no notice of
final determination not to abate interest pursuant to section
6404(e) was issued. In a case seeking the review of the failure
to abate interest, jurisdiction in this Court depends, in part,
upon the issuance of a valid notice of final determination not to
abate interest. Sec. 6404(g)(1); Rule 280(b)(1). Because no
notice of final determination denying a request for abatement of
interest was issued to petitioner Marie Banat, we hold that we
lack jurisdiction insofar as this case pertains to her.
To reflect the foregoing,
An appropriate order
will be issued.
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Last modified: May 25, 2011