REVIEW OF IRS FAILURE TO ABATE INTEREST.

Sec. 302. REVIEW OF IRS FAILURE TO ABATE INTEREST. (a) In general.— Section 6404 is amended by adding at the end the following new subsection: “(g) Review of Denial of Request for Abatement of Interest.— “(1) In general.— The Tax Court shall have jurisdiction over any action brought by a taxpayer who meets the requirements referred to in section 7430(c)(4)(A)(iii) to determine whether the Secretar’s failure to abate interest under this section was an abuse of discretion, and may order an abatement, if such action is brought within 180 days after the date of the mailing of the Secretary’s final determination not to abate such interest. “(2) Special Rules.— 110 STAT. 1458 “(A) Date of Mailing.— Rules similar to the rules of section 6213 shall apply for purposes of determining the date of the mailing referred to in paragraph (1). “(B) Relief.— Rules similar to the rules of section 6512(b) shall apply for purposes of this subsection. “(C) Review.— An order of the Tax Court under this subsection shall be reviewable in the same manner as a decision of the Tax Court, but only with respect to the matters determined in such order.”. (b) Effective Date.— The amendment made by this section shall apply to requests for abatement after the date of the enactment of this Act.