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Mankita v. Commissioner

Docket No. 14875-97.

78 T.C.M. 1216 (1999)

T.C. Memo. 1999-420

Gregorio and Viviana Mankita v. Commissioner.

United States Tax Court.

Filed December 27, 1999.

Attorney(s) appearing for the Case

Gregorio Mankita and Viviana Mankita, pro se. Anne W. Durning, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

On April 14, 1997, respondent issued a final determination disallowing petitioners' claim under section 6404(e) to abate interest related to petitioners' 1990 tax year. Petitioners timely filed a petition under section 6404(g)1 and Rule 280.

The issues for decision are:

1. Whether respondent's denial of petitioners' claim to abate interest relating to petitioners...

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