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BROWN v. COMMISSIONER

Docket No. 8538-98.

79 T.C.M. 1561 (2000)

T.C. Memo. 2000-61

Edgar & Doris Brown v. Commissioner.

United States Tax Court.

Filed February 28, 2000.

Attorney(s) appearing for the Case

Edgar Brown and Doris Brown, pro sese. Charles Pillitteri, for the respondent.

MEMORANDUM OPINION

THORNTON, Judge:

Respondent issued a final determination denying petitioners' claim for abatement of interest pursuant to section 6404(e).1 Petitioners timely filed a petition pursuant to section 6404(g) and Rule 280.2 The sole issue for decision is whether respondent's denial of petitioners' request to abate interest was an abuse of discretion.

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