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prerequisite to the Court’s jurisdiction and serves as a
taxpayer’s ‘ticket’ to the Tax Court.” Bourekis v. Commissioner,
110 T.C. 20, 26 (1998).
There is nothing in the record to indicate that respondent
intended for the notice of deficiency issued to petitioners to be
considered a final determination letter under section 6404(g).
See id.; Ho v. Commissioner, T.C. Memo. 1998-363. Further, the
parties stipulated that petitioners did not receive a written
notice of determination from respondent denying a request for
interest abatement.
Petitioners assert that their interest abatement claim is
properly before the Court because (1) interest was included in
the notice of deficiency and a proposed stipulation-decision
document, and (2) an Appeals officer verbally denied their
interest abatement claim. However, because of the absence of a
final determination letter denying a request for abatement of
interest, the Court lacks jurisdiction under section 6404(g) to
decide this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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