Jeffrey R. Taylor - Page 2

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               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Carleton D. Powell pursuant to Rules 180, 181, and 183.               
          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.  The Court agrees with and adopts the opinion of the             
          Special Trial Judge, which is set forth below.                              
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               POWELL, Special Trial Judge: This case involves the denial             
          of a request by petitioner to abate interest under section                  
          6404(e).1  On December 14, 1997, petitioner submitted two Forms             
          843 (Claim for Refund and Request for Abatement) to respondent.             
          The requests pertained to the interest due on the deficiencies              
          for the taxable years 1986 and 1987.  By letter dated May 6,                
          1998, the requests were denied, and petitioner sought review by             
          the Appeals Office.  On July 9, 1998, the Appeals Office also               
          denied the requests.  On September 21, 1998, petitioner filed a             
          petition for review of that determination with this Court.  At              
          the time that the petition for review was filed, petitioner                 
          resided in Tigard, Oregon.                                                  
               The facts may be summarized as follows.  Petitioner filed              
          joint Federal income tax returns with his then wife, Janet E.               

                    Unless otherwise indicated, section references are to             
          the Internal Revenue Code applicable for the periods involved.              

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