T.C. Memo. 2004-139
UNITED STATES TAX COURT
ROBERT B. KEMP, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5330-02. Filed June 10, 2004.
John P. Konvalinka, for petitioner.
Monica D. Armstrong, for respondent.
MEMORANDUM OPINION
GALE, Judge: Respondent issued a notice of final
determination denying petitioner’s claim for an abatement of
interest on his 1989 and 1990 Federal income tax liabilities.
Petitioner timely filed a petition for review with this Court
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