Scott Thomas and Jennifer Gundry - Page 7




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          deficiency has been assessed, nor can any assessment be made                
          until the decision in this case is entered.  Petitioners may file           
          with respondent an administrative request for abatement of any              
          interest assessed.  If, in a notice of final determination,                 
          petitioners' request is denied, petitioners may then petition               
          this Court for a review of that determination.  However, this               
          Court will order an abatement only if it is shown that the                  
          Commissioner abused his discretion in denying the abatement.  See           
          sec. 6404(i);3 Rule 280(b); Krugman v. Commissioner, 112 T.C.               
          230, 239 (1999).                                                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


          Decision will be entered                                                    
          for respondent.                                                             













               3    Sec. 6404(g) was redesignated sec. 6404(i) by the                 
          Internal Revenue Service Restructuring & Reform Act of 1998, Pub.           
          L. 105-206, secs. 3305(a), 3309(a), 112 Stat. 685, 743, 745.                





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