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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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