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this case insofar as the petition represents an attempt to invoke
the Court's jurisdiction pursuant to section 6213(a). Similarly,
petitioner may not invoke the Court's jurisdiction pursuant to
section 7481(c), under which the Court's authority to redetermine
interest is limited to interest on a deficiency that has been
redetermined by a decision of the Court and assessed under
section 6215.
The Court is equally satisfied that jurisdiction is lacking
under section 6404(g). Although petitioner admits that he did
not file a formal request for abatement of interest with
respondent, petitioner contends that the Court should consider
the letter that he received from respondent's Problem Resolution
Office as the equivalent of a denial of a request for abatement
of interest. We find petitioner's reliance on the Problem
Resolution Office letter to be misplaced given that the letter
merely addresses petitioner's contention that he is not liable
for interest based upon the Form 4549 that he executed for the
taxable year 1991. The letter does not indicate that any
consideration was given to a request for abatement of interest
pursuant to section 6404. In the absence of a specific request
for abatement of interest and the Commissioner's final
determination denying such request, the Court does not have
jurisdiction to consider this matter pursuant to section 6404(g).
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Last modified: May 25, 2011