Harold L. and Gladys M. Humberson - Page 19

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          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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