Jesse and Tawara Goode - Page 19

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          those instances where respondent has made an interest assessment            
          and such assessment is attributable in whole or in part to “any             
          unreasonable error or delay” by respondent in performing a                  
          “ministerial or managerial act”.  Sec. 6404(e).  Therefore,                 
          according to respondent, because the limited exception to section           
          6404(b) set forth in section 6404(h) is predicated on the                   
          issuance of a final determination concerning an interest                    
          abatement claim, interest suspension claims under section 6404(g)           
          do not qualify because they are nondiscretionary.  See Rev. Proc.           
          2005-38, supra.                                                             
               The applicability of section 6404(b) to petitioner’s                   
          interest suspension claim under section 6404(g) is not plainly              
          demonstrated by the statutory construction, since the                       
          jurisdictional ban expressly governs abatement claims regarding             
          assessments of tax, and an assessment has yet to occur in this              
          case.  However, irrespective of any perceived ambiguity inherent            
          in section 6404(b), it is a long-standing principle that this               
          Court generally lacks jurisdiction over issues involving                    
          interest.  Melin v. Commissioner, 54 F.3d 432, 434 (7th Cir.                
          1995); Bourekis v. Commissioner, 110 T.C. 20, 24-25 (1998); 508             
          Clinton St. Corp. v. Commissioner, 89 T.C. 352, 354 (1987).                 
          Petitioners’ arguments comprise the bare assertion to their                 
          entitlement to a suspension of interest under section 6404(g);              
          petitioners adduce no authority to override the well-established            






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