Raymond Wright - Page 1

                                 T.C. Memo. 2002-312                                  

                               UNITED STATES TAX COURT                                

                            RAYMOND WRIGHT, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6240-01L.             Filed December 26, 2002.              

                    P failed to file returns for 1987 and 1989.  P                    
               received a notice of deficiency for 1987 and 1989.  P                  
               petitioned the Court.  The Court ruled for R, and P                    
               appealed.  The Court of Appeals affirmed our decision.                 
                    R sent a Notice of Intent to Levy and Notice of                   
               Your Right to a Hearing to P for 1987 and 1989.  P                     
               requested a sec. 6330, I.R.C., hearing.  R held a sec.                 
               6330, I.R.C., hearing with P.  R determined that R                     
               could proceed with the proposed levy action.                           
                    Held:  P raised the issue of interest abatement at                
               the sec. 6330, I.R.C., hearing.  Therefore we have                     
               jurisdiction over this issue.  Katz v. Commissioner,                   
               115 T.C. 329 (2000).                                                   
                    Held, further, P is not entitled to interest                      
               abatement for amounts greater than those abated or                     
               conceded by R because P failed to file returns for 1987                
               and 1989 and failed to pay in full the amount of tax he                
               owed for those years.                                                  

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