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petitioners. Petitioners counter that respondent should be
required to grant or deny a request for abatement of interest
within a reasonable amount of time and that respondent's failure
to act in this case should be treated as the equivalent of a
denial of petitioners' request for abatement of interest.
In Bourekis v. Commissioner, 110 T.C. 20 (1998), the
taxpayers filed a petition with the Court in which they attempted
to invoke the Court's jurisdiction under section 6404(g) based on
the assertion that the Court should treat a notice of deficiency
issued to the taxpayers as the Commissioner's final determination
letter under section 6404(g). The Commissioner moved to dismiss
and to strike the petition for lack of jurisdiction insofar as
the petition referred to the Court's jurisdiction under section
6404(g). In granting the Commissioner's motion to dismiss, we
first noted that the Commissioner's final determination letter
under section 6404(g) "is a prerequisite to the Court's
jurisdiction and serves as a taxpayer's 'ticket' to the Tax
Court." Bourekis v. Commissioner, supra at 26; see Kraft v.
Commissioner, T.C. Memo. 1997-476. Further, relying on the body
of judicial opinions holding that, for a document to qualify as a
valid notice of deficiency under section 6213(a), the
Commissioner must intend for the letter to constitute a notice of
deficiency, we held that the Commissioner likewise must intend
for a letter to constitute a notice of final determination under
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