Jackie H. Hunt - Page 4

                                        - 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  

Last modified: May 25, 2011