- 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.
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