T.C. Memo. 1997-454
UNITED STATES TAX COURT
JOHN G. GOETTEE, JR., and MARIAN GOETTEE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26591-96. Filed October 6, 1997.
John G. Goettee, Jr., and Marian Goettee, pro se.
Pamela S. Wilson and Helen F. Rogers, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction and respondent's Motion for Partial Summary
Judgment. Respondent asserts that the Court lacks jurisdiction
pursuant to section 6404(g) to review respondent's denial of
petitioners' requests for abatement of interest.1 In the
1 All section references are to the Internal Revenue Code
as amended, unless otherwise indicated. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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