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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).
Discussion
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
Interest.--
(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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