Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 12

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          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 on             





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