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the tax liabilities or the additions to tax with respect to the
taxable years at issue.
On August 29, 2001, petitioner attended a hearing in person
at respondent’s Appeals Office in San Jose, California. At the
hearing, petitioner did not dispute the amount of the tax
liabilities and additions to tax. Petitioner made a request for
interest abatement at the hearing.
On August 30, 2001, respondent’s Appeals officer sent a
letter to petitioner which, in part, discussed petitioner’s claim
for an abatement of interest.
On May 6, 2002, the Appeals Office issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. The Appeals Office determined in
relevant part, that interest should not be abated with respect to
petitioner’s 1992 and 1993 taxable years.
Petitioner contends that respondent’s refusal to abate
interest was an abuse of discretion.
If, as part of a section 6330 hearing, a taxpayer makes a
request for abatement of interest, we have jurisdiction over the
request for abatement of interest that is the subject of
respondent’s collection activities. Katz v. Commissioner, 115
T.C. 329, 340-341 (2000); Wright v. Commissioner, T.C. Memo.
2002-312. Generally, this 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
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