- 4 - 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.Page: Previous 1 2 3 4
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