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Kincaid v. Commissioner

Docket No. 21682-97.

78 T.C.M. 1213 (1999)

T.C. Memo. 1999-419

David and Barbara Kincaid v. Commissioner.

United States Tax Court.

Filed December 27, 1999.

Attorney(s) appearing for the Case

David Kincaid and Barbara Kincaid, pro se. Doreen M. Susi and David W. Otto, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent issued a final determination disallowing petitioners' claim for abatement of interest relating to petitioners' 1979 and 1982 tax years. Petitioners timely filed a petition under section 6404(g)1 and Rule 280.

The issues for decision are:

1. Whether respondent's denial of petitioners' claim for abatement of interest that accrued after 1987

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