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motion. During the hearing, counsel for petitioners submitted to
the Court as an exhibit a letter that petitioners had recently
received from Appeals Officer Samuel E. Fish assigned to
respondent's Baltimore Appeals Office. The letter, dated August
20, 1998, states that petitioners' request for abatement of
interest had been transferred from the Richmond Appeals Office to
the Baltimore Appeals Office to ensure impartiality in the review
process insofar as the Richmond Appeals Office may have
contributed to alleged delays giving rise to petitioners' request
for abatement of interest. The letter further states that,
although there is no basis for granting petitioners' request for
abatement of interest, petitioners cannot invoke the Court's
jurisdiction to review the matter until respondent issues a final
determination letter denying petitioners' request.
At the hearing, respondent informed the Court that a final
determination letter would be issued to petitioners at some time
in the near future depending upon the result of an appeals
conference with petitioners.
Discussion
The question presented is whether the Court has jurisdiction
pursuant to section 6404(g) to review the Commissioner's failure
to grant petitioners' request for abatement of interest for 1992.
The Tax Court is a court of limited jurisdiction, and we may
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