Maurice C. Sainte-Yves - Page 4




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          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.                                                          




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