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right to be notified of or to participate in the administrative
proceedings relating to Ms. Bacon’s application for relief from
joint and several liability under former section 6013(e) and
(2) that petitioner lacks standing to challenge respondent’s
determination to grant Ms. Bacon such relief under former section
6013(e). See 26 U.S.C. sec. 6013(e) (1994); Estate of Ravetti v.
United States, 37 F.3d 1393, 1395-1396 (9th Cir. 1994).
Petitioner requests in the alternative that the Court waive
any (1) interest imposed by section 6601 on the assessed 1990 tax
deficiency during the period February 14, 1995, through December
31, 1998, and (2) penalties assessed by respondent with respect
to the assessed 1990 tax deficiency.
With respect to petitioner’s alternative request that the
Court waive any interest with respect to the assessed 1990 tax
deficiency imposed by section 6601 that respondent assessed
against him, the record does not establish whether petitioner
raised at his Appeals Office hearing that interest should not
have accrued on the assessed 1990 tax deficiency during the
period February 14, 1995, through December 31, 1998. Assuming
arguendo (1) that the record before us had established that
petitioner raised at his Appeals Office hearing that interest
should not have accrued on the assessed 1990 tax deficiency
during that period, (2) that we considered petitioner’s alterna-
tive request regarding interest to be a request for abatement of
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