Charles M. Corbalis & Linda J. Corbalis v. Commissioner

OPINION

Cohen, Judge:

This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. The primary issue for decision is whether section 6404(h) applies to denials of interest suspension under section 6404(g). If so, we must decide whether the notice from which petitioners seek review is a final determination for purposes of section 6404(h)(1). All section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Background

The operative facts are set forth in respondent’s…