Robert and Linda Yuen - Page 11

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          100, we declined to consider the taxpayers' argument that they              
          could resubmit their request for abatement of interest after July           
          30, 1996, and thereby qualify to invoke the Court's jurisdiction            
          under section 6404(g).                                                      
               In sum, the Court has concluded that section 302(b) of TBOR            
          2, 110 Stat. 1458, which provides that section 6404(g) applies              
          "to requests for abatement after the date of the enactment of               
          this Act", limits the Court's jurisdiction to the review of the             
          denial of requests for abatement of interest where the denial               
          occurs after July 30, 1996.  See White v. Commissioner, supra;              
          Banat v. Commissioner, supra.                                               
               Consistent with White v. Commissioner, supra, and Banat v.             
          Commissioner, supra, the Court lacks jurisdiction to review                 
          respondent's March 1996 denial of petitioners' request for                  
          abatement of interest filed in September 1995.  Moreover, we                
          agree with respondent that petitioners' resubmission of their               
          request for abatement of interest to respondent on January 16,              
          1998, which presented the same claim and ground for relief as               
          their prior submissions, does not provide a basis for the Court             
          to exercise jurisdiction over the petition filed herein.                    
          Although section 302(b) of TBOR 2 does not expressly address                
          whether a taxpayer may invoke the Court's jurisdiction by                   
          resubmitting a previously denied request for abatement of                   
          interest after the effective date of section 6404(g), we are not            

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