George N. and Maggie Ahmaogak - Page 2

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                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               CARLUZZO, Special Trial Judge:  On February 28, 2001,                  
          respondent issued a notice of final determination denying in part           
          petitioners’ request to abate interest on their 1989 Federal                
          income tax liability.  In response to that notice, petitioners              
          timely petitioned this Court for a review of respondent’s denial.           
          Our jurisdiction is established by section 6404(h).2  The issue             
          for decision is whether respondent’s failure to abate interest on           
          petitioners’ 1989 Federal income tax liability is an abuse of               
          discretion.                                                                 
                                     Background                                       
               Petitioners resided in Barrow, Alaska, at the time the                 
          petition was filed.  The facts in this case, all of which have              
          been stipulated, are easily summarized.                                     
               Petitioners are husband and wife.  They filed a timely joint           
          1989 Federal income tax return.3  Computational errors were made            
          on the return, and as a result the total tax liability reported             
          on the return was understated.  A notice was sent to petitioners            




               2  Sec. 6404(h) was previously designated sec. 6404(i).  See           
          Victims of Terrorism Tax Relief Act of 2001, Pub. L. 107-134,               
          sec. 112(d)(1)(B), 115 Stat. 2435.                                          
               3  The return has not been included in the record.  Details            
          of the return are set forth in a document prepared by                       
          respondent’s Appeals officer in response to petitioners’                    
          administrative claim for interest abatement.  The parties                   
          stipulated the truth of the factual portions of this document.              




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