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