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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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Last modified: May 25, 2011