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 byPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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