MEMORANDUM OPINION
WHALEN, Judge:
This is an action for review of the Commissioner's failure to abate interest under section 6404(e). All section references are to the Internal Revenue Code, as amended. The Commissioner mailed to petitioner a notice of final determination not to abate interest under section 6404, relating to interest that accrued with respect to petitioner's taxable years 1998 and 1999. Petitioner filed an imperfect petition and an amended...
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