William Grant Lee - Page 1

                                   113 T.C. No. 10                                    

                               UNITED STATES TAX COURT                                

                          WILLIAM GRANT LEE, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7263-97.                  Filed August 18, 1999.            

                    P and his former wife claimed losses from a tax                   
               shelter partnership on their 1980 Federal income tax                   
               return.  In April 1984, R issued a notice of deficiency                
               denying those losses.  In July 1984, P filed a petition                
               in this Court contesting the denial of the losses.                     
                    P's case was not resolved until 1995 when P and R                 
               entered a settlement agreement.  Pursuant to the                       
               settlement agreement, the Court entered a decision that                
               there was a deficiency in P's Federal income tax for                   
               1980.  In 1995, R granted P's former wife innocent                     
               spouse relief pursuant to sec. 6013(e), I.R.C.                         
                    Pursuant to sec. 6404(e), I.R.C., P requested an                  
               abatement of interest on his 1980 Federal income tax.                  
               In November 1996, R issued a notice of final                           
               determination denying P's claim to abate interest.  P                  
               filed a petition for review of R's failure to abate                    

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