§64041

The sole issue for decision is whether respondent' s SERVED JUL 3 0 2008 - 2 - decision pursuant to section 64041 not to abate assessments of interest relating to petitioner's 1994 and 1995 taxable years was an abuse of discretion .

MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: Respondent denied petitioners’ request under section 64041 for abatement of interest on their Federal income tax deficiency for 1984.

MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: On December 19, 2001, respondent issued a notice of final determination denying petitioners’ claim under section 64041 for abatement of interest on income tax liabilities 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time the petition was (continued...) - 2 - for 1993, 1994, and 1995.