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to decide income, gift, and estate tax cases, we generally have
jurisdiction over additions to tax for failure to pay those taxes
for purposes of section 6330(d)(1)(A). See sec. 6214(a); Downing
v. Commissioner, supra.
Respondent assessed the underpayment of income tax (which
has since been paid) shown on petitioners’ 1997 return, as well
as the additions to tax under sections 6654(a) and 6651(a)(1) and
(2) with respect to the delays in payment of the tax. We have
jurisdiction to review respondent’s determinations under section
6330 with respect to petitioners’ liability for the additions to
tax.
3. Extensions of Time To File and Pay
Although MSC originally claimed never to have received a
Form 4868 from petitioners for 1997, respondent conceded in the
notice of deficiency that petitioners did file a Form 4868, and
that the IRS approved petitioners’ request for an additional
extension of time to file their return by October 15, 1998.
Respondent did not approve petitioners’ request for an extension
of time to pay their tax liability.
The news release stated that most tax returns and payments
“normally” due on October 15, 1998, from taxpayers residing in
Alabama counties affected by Hurricane Georges would not be due
until November 16, 1998. Respondent claims the news release did
not apply to petitioners because their 1997 tax liability and
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