Robert T. Brewer - Page 8

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               In addition, we do not have jurisdiction to abate the                  
          interest on petitioner’s 1999 deficiency.  Under section                    
          6404(h)(1), the Tax Court may review the Secretary’s failure to             
          abate interest only after the Secretary makes a final                       
          determination not to abate interest.  See also Rule 280(b).                 
          Petitioner has not demonstrated that respondent has made a final            
          determination with respect to abatement of the interest on                  
          petitioner’s 1999 deficiency.                                               
               To reflect the foregoing,                                              


                                                  An order will be issued             
                                             denying petitioner’s motion to           
                                             vacate the stipulated decision           
                                             entered September 13, 2004.              
























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