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HUNT v. COMMISSIONER

Docket No. 5681-02.

86 T.C.M. 426 (2003)

T.C. Memo. 2003-283

Jackie H. Hunt v. Commissioner.

United States Tax Court.

Filed October 2, 2003.

Attorney(s) appearing for the Case

Hugh O. Mussina, for the petitioner.

Audrey M. Morris, for the respondent.

MEMORANDUM OPINION

GOEKE, Judge:

On September 18, 2001, respondent issued a notice of final determination disallowing petitioner's claim for abatement of interest on income tax liabilities for 1982. Petitioner timely filed a petition with this Court on March 11, 2002, for review of respondent's failure to abate interest. The issue for decision is whether petitioner is entitled to an abatement of interest under section 6404(g).1

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