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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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