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Commissioner's failure to abate the additions to tax and interest
associated with his 1987 and 1988 tax years. At trial and on
brief, petitioner narrowed his request for review to 1988.
Discussion
A. Abatement of Additions to Tax
This Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. See Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Section 6404(g)6 does not give this Court jurisdiction to review
respondent’s failure to abate additions to income tax. See
Krugman v. Commissioner, 112 T.C. 230, 237 (1999). Therefore, we
may not review the Commissioner’s failure to abate the additions
to tax associated with petitioner’s 1988 tax year.
B. Abatement of Interest
The Commissioner's authority to abate an assessment of
interest involves the exercise of discretion, and this Court
gives due deference to the Commissioner's discretion. See
Woodral v. Commissioner, 112 T.C. 19, 23 (1999); Mailman v.
Commissioner, 91 T.C. 1079, 1082 (1988). However, this Court may
order abatement where the Commissioner abuses his discretion by
6 Sec. 6404(g) was redesignated sec. 6404(i) by the
Internal Revenue Service Restructuring and Reform Act of 1998,
Pub.L. 105-206, secs. 3305(a), 3309(a), 112 Stat. 743, 745.
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