The Appellant (hereinafter referred to as "the Taxpayer") is seeking abatement of interest assessed by the Appellee (hereinafter referred to as "the Commissioner") for the 1999 tax year, to which the Commissioner has denied. The question presented for review by the Supreme Court of the United States of America is whether the Fifth Circuit Court of Appeals erred in holding that the Taxpayer was not entitled to interest abatement under 26 U.S.C.A. § 6404(e) when it relied on Lee v. Commissioner, which has been distinguished by more recent case law.

Whether the Taxpayer was entitled to interest abatement under 26 U.S.C.A. § 6404(e)