MEMORANDUM OPINION
MARVEL, Judge:
On March 19, 1999, respondent issued a notice of final determination denying petitioners' claim to abate interest for the taxable year 1993. On April 19, 1999, petitioners filed a timely petition to review respondent's determination. The only issue for decision is whether petitioners are entitled to an abatement of interest pursuant to section 6404(e).
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