- 19 - additional tax imposed by section 72(t). See O'Connor v. Commissioner, T.C. Memo. 1994-170; Wheeler v. Commissioner, T.C. Memo. 1993-561; cf. Dorsey v. Commissioner, T.C. Memo. 1995-97; Brown v. Commissioner, T.C. Memo. 1995-93. Interest Finally, having concluded that petitioners are liable for the deficiency in income tax, including the 10-percent additional tax imposed by section 72(t), we address petitioner's contention that they should be relieved of liability for interest on the deficiency. Petitioners impressed the Court as honest and conscientious taxpayers. Unfortunately, they experienced some frustration during the examination of their 1990 income tax return. Although the Court can appreciate petitioners' frustration, we must nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner, 92 T.C. 749, 752 (1989); LTV Corp. v. Commissioner, 64 T.C. 589, 597 (1975); see sec. 6404(e); Marine v. Commissioner, 92 T.C. 958, 994 (1989), affd. without published opinion 921 F.2d 280 (9th Cir. 1991); 508 Clinton St. Corp. v. Commissioner, 89 T.C. 352 (1987). Although there are certain narrowly defined exceptions to this rule, none of them apply in this case. See, e.g., sec. 7481(c); Bax v. Commissioner, 13 F.3d 54 (2d Cir. 1993). In short, it is simply not within our power in this case to relieve petitioners from any part of the interest on the deficiency that will be due.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011