Marvin L. White and Phyllis White - Page 7

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          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.               

















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