- 13 - respondent determine a deficiency in tax. Sec. 6665(b); Meyer v. Commissioner, 97 T.C. 555, 562 (1991). We conclude that we lack jurisdiction under section 6404(g) to decide petitioner's claim that respondent improperly refused to abate the $147.21 addition to tax. B. Abatement of Interest 1. Contentions of the Parties The parties agree that respondent's monthly payment notices had incorrect payoff figures, but they disagree about the effect of respondent's error. Petitioner contends that he is not liable for interest for 1985 because he fully complied with respondent's payment notices, in which respondent repeatedly said the payments included interest. He contends that respondent should not charge interest after establishing payment terms which he fully met. Petitioner contends that respondent's failure to abate interest that accrued from April 15, 1986, to April 11, 1993, is an abuse of discretion. Respondent concedes that petitioner is entitled to an abatement of interest which accrued on his deficiency and addition to tax from April 12, 1993 (the date that respondent first told petitioner that he owed tax and an addition to tax, but incorrectly failed to notify him that he owed interest), to August 9, 1995 (the day respondent corrected the error and firstPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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