- 33 -
reported generated respondent's audit. The information reported
was sufficient to apprise respondent of and enable respondent to
identify the potential controversy involved here; that is,
whether petitioners properly treated the stock option proceeds as
long-term capital gain.
We hold that petitioners adequately disclosed the
information and are not liable for the addition to tax under
section 6661.6
Interest
Petitioners argue that we should abate interest on the
income tax deficiency pursuant to section 6404(e) because of
respondent's delay in issuing the notice of deficiency.
Specifically, petitioners assert that respondent was dilatory in
issuing the notice of deficiency, thus increasing the interest
payable.
The United States Tax Court is a court of limited
jurisdiction. See sec. 7442; Wilt v. Commissioner, 60 T.C. 977,
978 (1973). New section 6404(g), added to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, 110 Stat. 1452, 1457 (1996), authorizes this Court to
review the Secretary's failure to abate interest only with
respect to requests for abatement made after July 30, 1996.
Because these cases do not involve a request for abatement made
6 Accordingly, we do not reach petitioners' argument with
respect to sec. 6661(c).
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