- 6 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011