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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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