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exercise our jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Section 6404(g), enacted as section 302(a) of the Taxpayer
Bill of Rights 2 (TBOR 2), Pub. L. 104-168, 110 Stat. 1457
(1996),2 provides in pertinent part as follows:
(g) Review of Denial for Abatement of Interest.--
(1) In General.--The Tax Court shall have
jurisdiction over any action brought by a taxpayer who
meets the requirements referred to in section
7430(c)(4)(A)(ii) to determine whether the Secretary's
failure to abate interest under this section was an
abuse of discretion, and may order an abatement, if
such action is brought within 180 days after the date
of the mailing of the Secretary's final determination
not to abate such interest.
In sum, the Court is vested with jurisdiction to review the
Commissioner's denial of a taxpayer's request for abatement of
interest if the taxpayer files a petition with the Court within
180 days after the date that the Commissioner mails to the
taxpayer a valid final determination not to abate interest. Sec.
6404(g)(1); Rule 280(b); Banat v. Commissioner, 109 T.C. 92, 95
(1997).
Section 302(b) of TBOR 2, 110 Stat. 1458, provides that
section 6404(g) applies "to requests for abatement after the date
2 Sec. 6404(g) subsequently was redesignated sec. 6404(i)
under the Internal Revenue Service Restructuring and Reform Act
of 1998, Pub. L. 105-206, secs. 3305(a) and 3309(a), 112 Stat.
743, 745, effective with respect to tax years beginning after
Dec. 31, 1997.
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