Marvin L. White and Phyllis White - Page 1

                                    109 T.C. No. 4                                     

                               UNITED STATES TAX COURT                                 

                  MARVIN L. WHITE AND PHYLLIS WHITE, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 20635-96.                   Filed August 5, 1997.            

                    Ps submitted requests for abatement of interest to                 
               the IRS, which were denied prior to July 30, 1996, the                  
               date of enactment of sec. 6404(g), I.R.C.  Ps now seek                  
               review of the failure to abate interest pursuant to                     
               sec. 6404(g).                                                           
                    Held:  We lack jurisdiction to review the denial                   
               of Ps' requests for abatement of interest.                              

               Robert L. White, for petitioners.                                       
               Christal Hillstead, for respondent.                                     

               COHEN, Chief Judge:  This case is before us on respondent's             
          Motion to Dismiss for Lack of Jurisdiction.  The issue is whether            

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