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section 6404(g)(1). In the April 1, 1998, letter, respondent
indicated that he was "rejecting" petitioner's claim and that the
letter was not a "denial" and did not constitute a "notice of
final determination letter". Consistent with our holding that
the Court lacks jurisdiction over a claim for abatement of
interest that has been resubmitted to respondent after having
been filed by a taxpayer and denied by respondent prior to the
effective date of section 6404(g)(1), we need not decide the
question of whether the April 1, 1998, letter constitutes a final
determination within the meaning of said provisions.
Consistent with the preceding discussion, we shall grant
respondent's Motion to Dismiss for Lack of Jurisdiction.
To reflect the foregoing,
An order will be entered
granting respondent's Motion
to Dismiss for Lack of Jurisdiction.
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Last modified: May 25, 2011