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CHRISTINA E. v. COMMISSIONER

Docket No. 7046-05.

92 T.C.M. 288 (2006)

T.C. Memo. 2006-201

Orlando J. and Christina E. Guerrero, v. Commissioner.

United States Tax Court.

September 20, 2006.

Attorney(s) appearing for the Case

Orlando J. and Christina E. Guerrero, pro sese;

Frederick J. Lockhart, Jr., for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

On October 19, 2004, respondent issued a notice of final determination disallowing petitioners' claim for abatement of interest accrued and assessed with respect to petitioners' unpaid Federal income tax liability for 2000. Petitioners timely filed a petition under section 6404(h)1 contesting respondent's determination. The only issue for decision is whether respondent's...

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