Robert and Linda Yuen - Page 1

















                                   112 T.C. No. 12                                    


                               UNITED STATES TAX COURT                                


                        ROBERT AND LINDA YUEN, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16025-98.              Filed March 19, 1999.                


                    On Sept. 19, 1995, Ps filed a request for                         
               abatement of interest with R for the taxable year 1990.                
               On Mar. 8, 1996, R notified Ps that their request for                  
               abatement of interest was denied.  On Jan. 16, 1998, Ps                
               resubmitted to R a request for abatement of interest                   
               for the taxable year 1990, presenting the same claim                   
               and basis for relief as their original request.  On                    
               Apr. 1, 1998, R informed Ps that R had "rejected" Ps'                  
               attempt to resubmit their request for abatement of                     
               interest on the ground that R had considered and denied                
               the request on Mar. 8, 1996.  On Sept. 24, 1998, Ps                    
               filed a petition with the Court seeking a review of R's                
               denial of their request for abatement of interest                      
               pursuant to sec. 6404(g) I.R.C. R moved to dismiss the                 
               petition for lack of jurisdiction.                                     
                    Held:  The Court lacks jurisdiction under I.R.C.                  
               sec. 6404(g) to review a request for abatement of                      
               interest that was filed by the taxpayer and denied by                  





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