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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