Robert and Marie Banat, petitioners v. commissioner of Internal Revenue, respondent

United States. Tax Court. Reports | August 1, 1997| | Copyright

ROBERT AND MARIE BANAT, PETITIONERS V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

Docket No. 2237-97. Filed August 5, 1997. H submitted requests for abatement of interest to the Internal Revenue Service prior to July 30, 1996, the date of enactment of sec. 6404(g), I.R.C. After July 30, 1996, R sent to H a notice of final disallowance of abatement of interest pursuant to sec. 6404(g). H and W filed a petition for review of the failure to abate interest. R filed a motion to dismiss for lack of jurisdiction as to H on the ground that the request for abatement of interest was submitted prior ...

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