- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011