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(Aug. 13, 1987).2 We review for abuse of discretion respondent’s
determination denying an abatement of interest. See sec.
6404(i); Lee v. Commissioner, 113 T.C. 145, 149 (1999).
We find no abuse of discretion here. As we understand
petitioners’ sole argument as to respondent’s refusal to abate
interest, they are not liable for any of the disputed interest
because, they state, they are not liable for the taxes and
penalties upon which the interest accrues. We have no
jurisdiction in this case to decide that issue as framed by
petitioners. We acquire our jurisdiction over this case from
section 6404(h), and that section does not authorize us to decide
in this case whether taxes or penalties assessed by the
respondent are proper. Sec. 6404(b); Krugman v. Commissioner,
112 T.C. 230, 237 (1999); Woodral v. Commissioner, 112 T.C. 19,
21 nn. 4&6 (1999); cf. Estate of Wenner v. Commissioner, 116 T.C.
284, 288 n.2 (2001). Given that petitioners have not established
that respondent abused his discretion as to his determination of
the disputed interest, we sustain that determination.
2 The final regulations under sec. 6404, which were issued
on Dec. 18, 1998, do not apply here in that they generally apply
to interest accruing on deficiencies or payments of tax described
in sec. 6212(a) for taxable years beginning after July 30, 1996.
Sec. 301.6404-2(d)(1), Proced. & Admin. Regs.
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