- 6 -
Commissioner, T.C. Memo. 1998-363 (declining to treat
respondent's 6-month delay responding to a formal request for
abatement of interest as final determination not to abate
interest).
In order for respondent to make a final determination
regarding a request for abatement of interest, section
301.6404-1, Proced. & Admin. Regs., directs that taxpayers first
file with respondent's appropriate office a formal request for
abatement, Form 843. See also Bourekis v. Commissioner, supra
at 26.
As of November 30, 2000, petitioner had not filed a Form
843, and respondent had not made a final determination with
regard to petitioner's request for abatement of the $5 of
interest. Accordingly, we lack jurisdiction thereof.
While we empathize with petitioner's situation in light of
the unclear letters petitioner received from respondent,1 we
simply do not have jurisdiction to grant petitioner relief from
either the addition to tax or the related interest.
1 In respondent's September 20, 1999, December 9, 1999, and
January 25, 2000, letters to petitioner, respondent did not
inform petitioner that before respondent could make a final
determination with regard to the abatement of the $5 of interest
petitioner must submit a Form 843, Claim for Refund and Request
for Abatement of Interest.
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