- 14 -
see also Washington v. Commissioner, 120 T.C. 114, 123-124
(2003).
We turn now to petitioners’ argument regarding respondent’s
failure to abate interest under section 6404, which we shall
review for abuse of discretion. See sec. 6404(h); see also Lee
v. Commissioner, 113 T.C. 145, 149 (1999). Section 6404(e)
permits respondent to abate interest with respect to an unreason-
able error or delay resulting from managerial and ministerial
acts.
Although petitioners allege in the petition that they should
be relieved from paying any interest with respect to each of
their taxable years 1999 through 2003, petitioners do not advance
any contentions or arguments in support of that allegation. On
the record before us, we find that petitioners have failed to
show that respondent abused respondent’s discretion in failing to
abate interest under section 6404 with respect to each of those
years.
Based upon our examination of the entire record before us,
we reject respondent’s determination in the notice of determina-
3(...continued)
failure to abate additions to tax under sec. 6404, on that
record, we hold that the Court does not have jurisdiction to
review petitioners’ request that we review any such failure. See
sec. 6404(h); see also Washington v. Commissioner, 120 T.C. 114,
124 n.15 (2003); Krugman v. Commissioner, 112 T.C. 230, 237
(1999).
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