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provide additional information for further consideration. The
record does not reflect that petitioner submitted any additional
information.
Subsequently, by certified letter dated August 25, 1999,
respondent issued a notice of final determination denying
petitioner’s claims for the abatement of interest for the taxable
years 1993, 1994, and 1995.
F. Tax Court Litigation
On February 23, 2000, petitioner commenced an action in this
Court by filing a petition, pursuant to section 6404(i) and Rules
280-284, for review of respondent’s failure to abate interest
with respect to the taxable years 1993, 1994, and 1995.8
Thereafter, on April 13, 2000, petitioner filed an amended
petition, alleging, inter alia, that “My claim is failure (error)
and delay in the audits of 1993, 1994 and 1995".
8 In pertinent part, sec. 6404(i) provides that
The Tax Court shall have jurisdiction over any action
brought by a taxpayer who meets the requirements referred to
in section 7430(c)(4)(A)(ii) to determine whether the
Secretary’s failure to abate interest under this section was
an abuse of discretion, and may order an abatement, if such
action is brought within 180 days after the date of the
mailing of the Secretary’s final determination not to abate
such interest.
Petitioner meets the net worth requirements of sec.
7430(c)(4)(A)(ii), and her action was timely commenced. See sec.
7502(a).
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