Robert and Linda Yuen - Page 12

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          persuaded that Congress intended for section 6404(g) to confer              
          jurisdiction in these circumstances.  Were we to hold otherwise,            
          the effective date provision, like a limitations period, would              
          fail to perform its purpose inasmuch as it could be defeated by             
          the simple expedient of filing in succession duplicative claims.            
          Cf. Trohimovich v. Commissioner, 776 F.2d 873 (9th Cir. 1985);              
          Huettl v. United States, 675 F.2d 239 (9th Cir. 1982).                      
          Consequently, we reject petitioners' contention that the                    
          resubmission of their request for abatement of interest and the             
          denial or rejection of their claim after the effective date of              
          section 6404(g) provides a basis for the Court to exercise                  
          jurisdiction in this case.                                                  
               The record in this case indicates that some of respondent's            
          agents may have given petitioners erroneous advice respecting               
          their right to file a petition for review with the Court.                   
          Assuming for the sake of argument that petitioners were                     
          erroneously advised to file the petition herein, erroneous advice           
          does not provide a basis for the Court to exercise jurisdiction             
          over a matter not authorized by statute.  See Odend'hal v.                  
          Commissioner, 95 T.C. 617, 624 (1990); Kraft v. Commissioner,               
          T.C. Memo. 1997-476.                                                        
               Respondent presents an alternative argument that the Court             
          lacks jurisdiction on the ground that the April 1, 1998, letter             
          does not constitute a final determination within the meaning of             

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