John G. Goettee, Jr., and Marian Goettee - Page 4

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          herein.  Petitioner John G. Goettee, Jr., appeared at the hearing           
          and offered argument in opposition to respondent's position.                
          Following the hearing, respondent filed a Motion to Dismiss                 
          for Lack of Jurisdiction and a memorandum in support of the                 
          motion.  Petitioners filed an objection to respondent's motion to           
          dismiss, to which respondent filed a reply.                                 
          Discussion                                                                  
          As a preliminary matter, we must decide whether the Court                   
          has jurisdiction over this matter.  The Tax Court is a court of             
          limited jurisdiction, and we may exercise our jurisdiction only             
          to the extent authorized by Congress.  Naftel v. Commissioner, 85           
          T.C. 527, 529 (1985).                                                       
               Section 6404(g), codified under section 302(a) of the                  
          Taxpayer Bill of Rights 2 (TBOR 2), Pub. L. 104-168, 110 Stat.              
          1452, 1457 (1996), provides the Tax Court with authority to                 
          review the Commissioner's denial of a taxpayer's request for                
          abatement of interest.  Section 6404(g) provides in pertinent               
          part as follows:                                                            
                    (g) Review Of Denial Of Request For Abatement Of                  
               Interest.--                                                            
                         (1) In General.--The Tax Court shall have                    
               jurisdiction over any action brought by a taxpayer who                 
               meets the requirements referred to in section                          
               7430(c)(4)(A)(ii) to determine whether the Secretary's                 
               failure to abate interest under this section was an                    
               abuse of discretion, and may order an abatement, if                    
               such action is brought within 180 days after the date                  
               of the mailing of the Secretary's final determination                  
               not to abate such interest. * * *                                      





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