OPINION
COHEN, Chief Judge:
This case is before us on respondent's motion to dismiss for lack of jurisdiction. The issue is whether the Court has jurisdiction pursuant to section 6404(g) to review respondent's determination denying petitioners' claims for abatement of interest. The resolution of this issue turns on the effective date of section 6404(g). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at...
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