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request for abatement of interest to respondent on January 16,
1998, and denial or rejection on April 1, 1998, provides a basis
for petitioners to invoke the Court's jurisdiction pursuant to
section 6404(g), notwithstanding that their original request for
abatement of interest was denied by respondent prior to July 31,
1996.
This case presents an issue concerning the Court's
jurisdiction under section 6404(g). Although we have not had the
opportunity to consider the specific question presented in this
case, we have analyzed the impact of the effective date of
section 6404(g) on the Court's jurisdiction under slightly
different circumstances.
In Banat v. Commissioner, supra at 94-95, we held that the
taxpayer had properly invoked the Court's jurisdiction pursuant
to section 6404(g) with respect to a request for abatement of
interest filed with the Commissioner prior to the effective date
of section 6404(g) but denied by the Commissioner after the
effective date of the provision. See Goettee v. Commissioner,
T.C. Memo. 1997-454. On the other hand, in White v.
Commissioner, 109 T.C. 96, 99 (1997), we held that the Court
lacked jurisdiction pursuant to section 6404(g) to review the
Commissioner's denial of a request for abatement of interest
where the request was filed and denied prior to the effective
date of section 6404(g). In White v. Commissioner, supra at 99-
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