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WOODRAL v. COMMISSIONER

Docket No. 6385-98.

112 T.C. 19 (1999)

WILLIAM AND HELEN WOODRAL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 12, 1999.

Attorney(s) appearing for the Case

Robert C. Platt, for petitioners.

Usha Ravi and Ronald G. Dong, for respondent.

OPINION

VASQUEZ, Judge:

On March 26, 1998, the Commissioner issued a notice of final determination denying petitioners' claim to abate interest. Petitioners timely filed a petition under section 6404(g)1 and Rule 280. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The issue for decision...

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