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.
OPINION
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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