- 12 - subtitle A that is subject to interest computed at the increased rate prescribed in section 6621(c)(1). Because the only items in dispute in White concerned additions to tax, the underlying deficiency in tax having been previously assessed as a computational adjustment pursuant to section 6230(a)(1), we held that section 6621(c)(4) did not provide the Court with jurisdiction to redetermine the taxpayers' liability for increased interest under section 6621(c). Accord Odend'hal v. Commissioner, 95 T.C. 617 (1990). As in White v. Commissioner, supra, respondent issued a notice of deficiency to petitioners solely for additions to tax after assessing the underlying tax deficiency as a computational adjustment following the conclusion of the Irving & Co. partnership level proceedings. Consistent with White v. Commissioner, supra, it follows that we lack jurisdiction in this deficiency proceeding to redetermine petitioners' liability for interest computed at the increased rate prescribed in section 6621(c). We likewise agree with respondent that, under the circumstances presented, we do not have the authority to consider petitioners' liability for interest computed at the increased rate prescribed in section 6621(c) by virtue of our jurisdiction to determine an overpayment under section 6512(b). In short, the record shows that, despite petitioners' payment of $3,240.60 onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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