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abatement. Sec. 6404(i);2 Rule 280(b); Krugman v. Commissioner,
112 T.C. 230, 239 (1999). The Court, therefore, declines to pass
upon the merits of petitioner's claim for an abatement of
interest. Indeed, this Court has no jurisdiction over this issue
at this time.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
2 Sec. 6404(h) was redesignated sec. 6404(i) by the
Internal Revenue Service Restructuring & Reform Act of 1998, Pub.
L. 105-206, sec. 3309(a), 112 Stat. 745.
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Last modified: May 25, 2011