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PALIHNICH v. COMMISSIONER

Docket No. 10591-00.

86 T.C.M. 488 (2003)

T.C. Memo. 2003-297

Nicholas J. and Diane L. Palihnich v. Commissioner,

United States Tax Court.

Filed October 23, 2003.

Attorney(s) appearing for the Case

Kenneth R. Cohen, for the petitioners.

Shawna A. Early, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent issued a final determination disallowing petitioners' claim under section 6404(e) for abatement of interest related to petitioners' 1980 and 1981 tax years. Petitioners timely filed a petition under section 6404(g)1 and Rule 280.

The issue for decision is whether respondent's denial of petitioners' request to abate interest relating to petitioners' 1980...

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