Dai Ho and Young H. Cho - Page 8

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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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