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perceived as grossly unfair.” H. Rept. 99-426, at 844 (1985),
1986-3 C.B. (Vol. 2) 1, 844; S. Rept. 99-313, at 208 (1986),
1986-3 C.B. (Vol. 3) 1, 208.
B. Jurisdiction of the Tax Court
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Sec. 7442; Naftel v. Commissioner, 85 T.C. 527, 529
(1985). In proceedings brought by a taxpayer for a review of the
Commissioner’s denial of the taxpayer’s request to abate
interest, as in the present case, the jurisdiction of this Court
is limited solely to a determination as to whether the
Commissioner abused his discretion in declining to abate any
portion of the interest under section 6404. See sec. 6404(i);
Vanstone v. Commissioner, T.C. Memo. 2002-133.
“When reviewing the Commissioner’s determination pursuant to
section 6404, our inquiry is a factual one, and we proceed on a
case-by-case basis.” Jacobs v. Commissioner, T.C. Memo. 2000-
123. Since the Commissioner’s power to abate interest involves
the exercise of discretion, we give the Commissioner’s
determination due deference. Woodral v. Commissioner, 112 T.C.
19, 23 (1999). We review the Commissioner’s determination not to
abate interest applying an abuse of discretion standard. See
sec. 6404(i); Camerato v. Commissioner, supra.
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