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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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Last modified: May 25, 2011