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request for abatement of interest, we have jurisdiction over the
request for abatement of interest that is the subject of the
Commissioner’s collection activities. Katz v. Commissioner,
supra at 340-341. Generally, the Court considers only arguments,
issues, and other matters that were raised by the taxpayer at the
section 6330 hearing or otherwise brought to the attention of the
Appeals Office. Magana v. Commissioner, 118 T.C. 488, 493
(2002); Miller v. Commissioner, 115 T.C. 582, 589 n.2 (2000);
Sego v. Commissioner, supra at 612.
Petitioner’s hearing request is peppered with references to
Internal Revenue Service (IRS) errors and delays, including the
IRS’s failure to respond to petitioner, and it specifically
mentions abatement. Petitioner’s testimony made it clear to the
Court that he raised the issue of interest abatement any time he
was in contact with respondent.4
Furthermore, Appeals Officer Cayenne testified that she
recalled petitioner’s mentioning at the section 6330 hearing an
18-month delay, various other errors and delays by respondent,
and delays by the Appeals officer assigned to petitioner’s
4 We also note that in the underlying tax case petitioner
raised the issue of interest abatement as to his 1987 and 1989
tax years, but the Court concluded that petitioner’s request for
abatement of interest was premature--at that time there was
neither an assessment of such interest nor a final determination
by respondent not to abate interest. Wright v. Commissioner,
supra.
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Last modified: May 25, 2011