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overpayments to offset petitioners' 1990 tax deficiency.
Petitioners contend that interest should be abated to offset
expenses they incurred in hiring Feldman and traveling to Mexico
to obtain records to support their position in the audit. We
disagree. Taxpayers are required to maintain proper records.
See sec. 6001. The Government is not required to reimburse their
compliance costs.
8. Conclusion
We conclude that respondent's denial of petitioners’ claim
to abate interest from April 15, 1991, to the present relating to
their 1990 tax year was not an abuse of discretion.
B. Addition to Tax for Filing a Return and Paying Tax Late
Petitioners contend that they should not be liable for the
addition to tax under section 6651(a) for filing a return and
paying tax late. Petitioners contend that they filed their 1990
return late because petitioner's mother died in early February
1991.
We lack jurisdiction to decide whether petitioners are
liable for the addition to tax under section 6651(a) because
section 6404(g) does not give us jurisdiction to decide that
issue. See Krugman v. Commissioner, 112 T.C. at 237 (we lack
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