Rule 280. General

(a) Applicability: The Rules of this Title XXVII set forth the provisions which apply to actions for review of the Commissioner's failure to abate interest under Code Section 6404. Except as otherwise provided in this Title, the other Rules of Practice and Procedure of the Court, to the extent pertinent, are applicable to such actions for review.

(b) Jurisdiction: The Court shall have jurisdiction of an action for review of the Commissioner's failure to abate interest under this Title when the following conditions are satisfied:

(1) The Commissioner has mailed a notice of final determination not to abate interest under Code Section 6404.

(2) A petition for review of the Commissioner's failure to abate interest is filed with the Court within the period specified in Code Section 6404(g) by a taxpayer who meets the requirements of Code Section 7430(c)(4)(A)(ii).

Effective Date

Title XXVII sets forth procedures for actions under section 6404(g) of this title, as added by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104–168, 110 Stat. 1452 . Section 6404(g) of this title provides for review of the Commissioner's failure to abate interest and is applicable to requests for abatement after July 30, 1996, the date of enactment of the Taxpayer Bill of Rights 2. Similarly, the Rules of Title XXVII are effective with respect to actions for review of the Commissioner's failure to abate interest pertaining to requests for abatement after July 30, 1996.