- 7 - arguments are to no avail. As pointed out on numerous occasions, the jurisdiction of this Court is strictly limited by statute, and we may not enlarge upon that statutory jurisdiction. Breman v. Commissioner, 66 T.C. 61, 66 (1976). Our statutory authority pursuant to section 6404(g) is to decide whether the Commissioner's final determination not to abate interest was an abuse of discretion, and that section does not authorize us independently to receive and consider requests for abatement of interest. Further, future requests for abatement of interest which petitioners may or may not file with the IRS have no bearing on our jurisdiction in this proceeding. Because petitioners' requests for abatement of interest were made and denied prior to the enactment of section 6404(g), there is no applicable 180-day period. To reflect the foregoing, An order of dismissal for lack of jurisdiction will be entered.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011