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BANAT v. COMMISSIONER

Docket No. 2237-97.

109 T.C. 92 (1997)

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

United States Tax Court.

Filed August 5, 1997.

Attorney(s) appearing for the Case

Robert and Marie Banat, pro se.

Thomas J. Kerrigan, for respondent.

OPINION

COHEN, Chief Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction. The issue is whether the Court has jurisdiction pursuant to section 6404(g) to consider petitioners' claims seeking abatement of interest. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time the petition was filed, and all Rule references are to...

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