- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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