T.C. Memo. 2000-61
UNITED STATES TAX COURT
EDGAR & DORIS BROWN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8538-98. Filed February 28, 2000.
Edgar Brown and Doris Brown, pro sese.
Charles Pillitteri, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: Respondent issued a final determination
denying petitioners’ claim for abatement of interest pursuant to
section 6404(e).1 Petitioners timely filed a petition pursuant
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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