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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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