(a) Commencement of Action: An action for review of the Commissioners failure to abate interest under Code section
6404 shall be commenced by filing a petition with the Court. See Rule
20, relating to commencement of case; Rule
22 relating to the place and manner of filing the petition; and Rule
32, regarding the form of pleadings.
(b) Content of Petition: A petition filed pursuant to this Rule shall be entitled Petition for Review of Failure to Abate Interest under Code Section
6404 and shall contain the following:
(1) In the case of a petitioner other than a corporation, the petitioners name and legal residence; in the case of a corporate petitioner, the petitioners name and principal place of business or principal office or agency; and, in all cases, the petitioners mailing address and identification number (e.g., Social Security number or employer identification number). The mailing address, legal residence, and principal place of business, or principal office or agency, shall be stated as of the date that the petition is filed.
(2) The date of the notice of final determination not to abate interest and the City and State of the office of the Internal Revenue Service which issued the notice.
(3) The year or years or other periods to which the failure to abate interest relates.
(4) Clear and concise lettered statements of the facts on which the petitioner relies to establish that the Commissioners final determination not to abate interest was an abuse of discretion.
(5) A statement that the petitioner meets the requirements of Code section
7430 (c)(4)(A)(ii).
(6) The signature, mailing address, and telephone number of each petitioner or each petitioners counsel, as well as counsels Tax Court bar number.
(7) As an attachment, a copy of the notice of final determination denying (in whole or in part) the requested abatement.
