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