- 4 - treatment in regard to his request for abatement of interest as other Barrister partners had received from respondent (i.e., approval). Respondent’s San Francisco Appeals Office sustained respondent’s denial of petitioner’s request for abatement of interest and denied petitioner’s request for a transfer of his appeal. Petitioner filed under section 6404(i) the instant petition for review of respondent’s denial of petitioner’s request for abatement of interest. OPINION Generally, we have jurisdiction to review respondent’s denial of a taxpayer’s request under section 6404(e)(1) for abatement of interest. Sec. 6404(i).2 2 In 1996, sec. 6404(g) (in 1998 redesignated as sec. 6404(i), and in 2002 redesignated as sec. 6404(h)) was enacted, which gave this Court jurisdiction to review respondent’s denial of a taxpayer’s request under sec. 6404(e)(1) for abatement of interest, effective for requests that were pending with respondent after July 30, 1996. See Victims of Terrorism Tax Relief Act of 2001, Pub. L. 107-134, sec. 112(d)(1)(B), (f), 115 Stat. 2434-2435; Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3305(a), 112 Stat. 743; Banat v. Commissioner, 109 T.C. 92, 95 (1997). Petitioner mailed a request for abatement of interest to respondent on July 7, 1996. Petitioner’s request for abatement of interest was denied by respondent on Aug. 7, 1996. Accordingly, we have jurisdiction under sec. 6404(i) to review respondent’s denial of petitioner’s request for abatement of interest. See id.Page: Previous 1 2 3 4 5 6 7 8 Next
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