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abatement of interest with respondent. See Rev. Proc. 87-42,
1987-2 C.B. 589 (requests for abatement of an assessment of
interest should be made on Form 843 (Claim for Refund and Request
for Abatement)). In this regard, neither Revenue Agent Kenley's
June 1996 letter, the examination report that accompanied that
letter, nor the notice of deficiency that petitioners received in
this case indicates that respondent has given any consideration
to whether it would be appropriate to abate an assessment of
interest in this case. Under the circumstances, we decline to
treat the notice of deficiency as a notice of final determination
not to abate interest under section 6404(g).
Petitioners' argument that the notice of final determination
not to abate interest that respondent issued to T. John and
Magdaline B. Tsalaky provides a basis for the Court to exercise
jurisdiction in this case is likewise misplaced. At best,
petitioners' argument is a request that we assume jurisdiction
under section 6404(g) based upon equitable considerations.
However, as a court of limited jurisdiction, we may not apply
equitable principles to assume jurisdiction over a matter not
authorized by statute. See Odend'hal v. Commissioner, 95 T.C.
617, 624 (1990), and cases cited therein. Absent a notice of
final determination not to abate interest on the deficiency in
their own tax, petitioners' attempt to invoke the Court's
jurisdiction under section 6404(g) must fail, and we so hold.
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