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this opinion shall not be treated as precedent for any other
case. After concessions by the parties, the issue for decision
is whether the Court has jurisdiction to determine whether
petitioner is liable for interest on the amount of tax owed.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Arkansas.
Petitioner, Dempsie Word, and his then wife Mae E. Word
timely filed a joint income tax return for 1996. The return
reflected tax due of zero, income tax withholding of $1,052, an
earned income credit of $2,447, and an overpayment of $3,499.
On March 31, 1997, respondent issued petitioner and Mae E.
Word a refund of $3,499. On January 13, 1999, respondent issued
petitioner and Mae E. Word a notice of deficiency for 1996
determining a deficiency in income tax of $3,983.
On July 15, 2004, petitioner timely filed a Form 8857,
Request for Innocent Spouse Relief, for 1996. Respondent issued
a Notice of Determination Concerning Your Request for Relief from
Joint and Several Liability under Section 6015 granting
petitioner partial relief pursuant to section 6015(c).
Petitioner filed his petition in response to the notice.
Petitioner requested relief of $3,983 but was granted relief of
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