MEMORANDUM OPINION
SWIFT, Judge:
This case is before us on respondent's motion to dismiss. The issue presented is whether we lack jurisdiction over petitioner's claims that an addition to tax under section 6654(a) should be waived and that assessed interest should be abated under section 6404.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.
Background
As...
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