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section 3305(a) of the Internal Revenue Service Restructuring and
Reform Act of 1998 (RRA 1998), Pub. L. 105-206, 112 Stat. 685,
743. Pursuant to RRA 1998, section 6404(g) is effective only for
tax years ending after July 22, 1998. Nerad v. Commissioner,
T.C. Memo 1999-376. Consequently, section 6404(g)(1) does not
apply because petitioner is seeking an abatement of interest on
her income tax liabilities for the taxable year 1982.3
Petitioner expressly states on brief that she is not seeking
relief under any subsection other than section 6404(g). She
raises no other issues, and has presented no other facts or
evidence to establish that she is entitled to interest abatement
if section 6404(g) does not apply. Based on the foregoing, we
hold that petitioner is not entitled to an abatement of interest
on the deficiency in income tax for 1982.
Decision will be entered
for respondent.
2(...continued)
the return without regard to extensions.
3 Since sec. 6404 was enacted, various subsections have been
redesignated. Petitioner mistakenly relies on effective date
language relating to current sec. 6404(h), not sec. 6404(g). As
explained above, sec. 6404(g) is only effective for tax years
ending after July 22, 1998.
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