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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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