107 T.C. No. 14
UNITED STATES TAX COURT
PEN COAL CORPORATION, f.k.a. P&C "BITUMINOUS COAL", INC.,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
PEN HOLDINGS, INC. AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 23670-95, 23672-95. Filed November 6, 1996.
Ps filed petitions for redetermination contesting,
inter alia, R's determination that Ps are liable for
interest computed at the increased rate prescribed in
sec. 6621(c), I.R.C., applicable to large corporate
underpayments of tax. R filed motions to dismiss for
lack of jurisdiction and to strike allegations relating
to Ps' liability for interest under sec. 6621(c).
Held: Sec. 6214(a) does not provide statutory
authority for this Court to redetermine Ps' liability for
interest computed at the increased rate prescribed in sec.
6621(c). Held, further, R's motions to dismiss for lack of
jurisdiction and to strike will be granted.
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