Robert and Linda Yuen - Page 2

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               the Commissioner prior to the effective date of sec.                   
               6404(g) I.R.C.  See White v. Commissioner, 109 T.C. 96,                
               99 (1997).  Held further:  Because Ps' original request                
               for abatement of interest for 1990 was filed and denied                
               prior to the effective date of sec. 6404(g) I.R.C., Ps'                
               resubmission of their request for abatement of interest                
               on Jan. 16, 1998, does not provide a basis for Ps to                   
               invoke the Court's jurisdiction pursuant to sec.                       
               6404(g) I.R.C.                                                         
               Robert and Linda Yuen, pro sese.                                       
               Laurel M. Robinson and Wendy Abkin, for respondent.                    

               COHEN, Chief Judge:  This case was assigned to Chief Special           
          Trial Judge Peter J. Panuthos pursuant to section 7443A(b)(4) and           
          Rules 180, 181, and 183.1  The Court agrees with and adopts the             
          opinion of the Special Trial Judge, which is set forth below.               
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
          PANUTHOS, Chief Special Trial Judge:  This matter is before                 
          the Court on respondent's Motion to Dismiss for Lack of                     
          Jurisdiction.  Respondent contends that the Court lacks                     
          jurisdiction under section 6404(g) to consider the petition filed           
          in this case.  As explained in greater detail below, we shall               
          grant respondent's motion.                                                  

               1  Section references are to the Internal Revenue Code, as             
          amended.  Rule references are to the Tax Court Rules of Practice            
          and Procedure.                                                              

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