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abatement of interest under section 6404(g).1 We hold that
section 6404(g) does not apply.
Background
The parties submitted this case fully stipulated. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. Petitioner resided in Mason, Texas, at
the time she filed her petition.
On her 1982 Federal income tax return, petitioner claimed a
$23,174 loss from Yuma Mesa Jojoba, Ltd. (the partnership). This
Court in Cactus Wren Jojoba, Ltd. v. Commissioner, T.C. Memo.
1997-504, filed November 10, 1997, upheld the Commissioner’s
determination denying research and experimental deductions of
$1,298,031 taken by the partnership for 1982. On October 13,
1998, petitioner’s claimed loss was disallowed in a tax
calculation which was made pursuant to the partnership level
proceedings, resulting in a deficiency in her 1982 Federal income
tax of $11,587. On December 18, 1998, respondent issued a
statutory notice of deficiency to petitioner for the taxable year
1982, determining additions to tax pursuant to sections
6653(a)(1) and (2), and 6661. On December 31, 1998, petitioner
filed a claim for abatement of the interest with respect to the
deficiency determination. On August 16, 1999, petitioner paid
the $11,587 deficiency.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code.
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