John G. Goettee, Jr., and Marian Goettee - Page 3

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          of interest were only partially allowed insofar as respondent               
          agreed to abate interest accruing during the period October 4,              
          1995 to September 20, 1996--which for the most part coincided               
          with the period that petitioners' requests for abatement were               
          under consideration by respondent.                                          
               On December 6, 1996, petitioners filed with the Court a                
          petition for review of respondent's denial of their requests for            
          abatement of interest.2  After filing an answer to the petition,            
          respondent filed a Motion for Partial Summary Judgment that                 
          petitioners' request for abatement respecting the taxable year              
          1978 was properly denied on the ground that respondent lacks the            
          authority to abate interest for the taxable year 1978.3                     
          Petitioners filed an opposition to respondent's Motion for                  
          Partial Summary Judgment.                                                   
          This matter was called for hearing at the Court's motions                   
          session held in Washington, D.C.  Counsel for respondent appeared           
          at the hearing and raised the argument that the Court lacks                 
          jurisdiction under section 6404(g) to consider the petition filed           



          2  At the time the petition was filed, petitioners resided                  
          at New Windsor, Maryland.                                                   
          3  At the hearing of this matter, counsel for respondent                    
          stated that respondent had erred insofar as the Nov. 13, 1996,              
          notice of disallowance provides for the abatement of a portion of           
          the interest assessed against petitioners for the taxable year              
          1978.  However, counsel for respondent stated that respondent               
          would not attempt to reverse the erroneous abatement.                       




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