T.C. Memo. 2003-283
UNITED STATES TAX COURT
JACKIE H. HUNT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5681-02. Filed October 2, 2003.
Hugh O. Mussina, for petitioner.
Audrey M. Morris, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: On September 18, 2001, respondent issued a
notice of final determination disallowing petitioner’s claim for
abatement of interest on income tax liabilities for 1982.
Petitioner timely filed a petition with this Court on March 11,
2002, for review of respondent’s failure to abate interest. The
issue for decision is whether petitioner is entitled to an
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