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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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