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7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: On June 2, 1999, respondent
issued a notice of final determination denying petitioner’s claim
for abatement of interest on a deficiency in petitioner’s Federal
income tax for the taxable year 1986. Petitioner timely filed a
petition with this Court pursuant to section 6404(i) and Rules
280-284. The issue for decision is whether respondent abused his
discretion by denying petitioner’s claim for abatement of
interest.2 We hold that respondent did not.3
FINDINGS OF FACT
Most of the facts have been stipulated, and are so found.
The stipulation of facts and supplemental stipulation of facts,
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.
2 To the extent that petitioner’s claim for abatement
includes a claim for abatement of tax, penalties, or additions to
tax, see infra Findings of Fact F, it is clear that this Court
lacks jurisdiction to consider such claim. See sec. 6404(b),
(e)(1); Krugman v. Commissioner, 112 T.C. 230, 237 (1999).
3 The Court directed respondent to file an opening brief
within 60 days after the conclusion of the trial and afforded
petitioner the opportunity of filing an answering brief within 30
days thereafter. Compare Rule 151(b)(2). Respondent timely
filed an opening brief; however, petitioner chose not to file an
answering brief.
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