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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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