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6659(c) or any sham or fraudulent transaction. Sec.
6621(c)(3)(A)(i), (v).
In the FPAAs issued to DGE 85-5 for 1985 and 1986,
respondent asserted that the individual partners might be liable
for section 6621(c) interest. As reflected in the orders and
decisions in Shorthorn Genetic Engg. 1982-2, Ltd. v.
Commissioner, T.C. Memo. 1996-515, the Tax Court determined that
it lacked jurisdiction over section 6621(c) interest at the
partnership level because such interest was not a partnership
item but an affected item. The difference between partnership
items and affected items and the impact this distinction has on
our jurisdiction are discussed below.
Respondent issued petitioner a Form 4549A-CG, in which
respondent determined that petitioner was liable for section
6621(c) interest. Respondent did not issue a notice of
deficiency because he treated the interest as a computational
matter.
Petitioner has not previously had the opportunity to dispute
his liability for section 6621(c) interest. Therefore, we have
jurisdiction under section 6330(d) to review petitioner’s
underlying tax liability as it relates to section 6621(c)
interest. See also sec. 6330(c)(2)(B). We review the section
6621(c) interest issue de novo. See Sego v. Commissioner, 114
T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182
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