Robert and Linda Yuen - Page 7

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          request for abatement of interest.  At the time the petition was            
          filed, petitioners resided in San Francisco, California.                    
          In response to the petition, respondent filed a Motion to                   
          Dismiss for Lack of Jurisdiction on the ground that petitioners'            
          request for abatement of interest was filed and denied prior to             
          the effective date of section 6404(g).  Petitioners filed an                
          objection to respondent's motion to dismiss asserting that their            
          petition is valid inasmuch as petitioners resubmitted their                 
          request for abatement of interest to respondent after the                   
          effective date of section 6404(g).                                          
               The question presented is whether the Court has jurisdiction           
          pursuant to section 6404(g) to review respondent's rejection or             
          denial of petitioners' request for abatement of interest for                
          1990.  The Tax Court is a court of limited jurisdiction, and we             
          may exercise our jurisdiction only to the extent authorized by              
          Congress.  Naftel v. Commissioner, 85 T.C. 527, 529 (1985).                 
          Section 6404(g), codified under section 302(a) of the                       
          Taxpayer Bill of Rights 2 (TBOR 2), Pub. L. 104-168, 110 Stat.              
          1452, 1457, provides in pertinent part as follows:                          
                    (g) Review of Denial of Request for Abatement of                  
                         (1) In general.--The Tax Court shall have                    
                    jurisdiction over any action brought by a taxpayer                
                    who meets the requirements referred to in section                 
                    7430(c)(4)(A)(ii) to determine whether the                        

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