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              As indicated, respondent moved to dismiss for lack of                  
          jurisdiction and to strike the allegations in the petitions                 
          concerning petitioners' liability for interest.  Respondent                 
          contends that this Court lacks jurisdiction in these proceedings            
          to redetermine petitioners' liability for interest under sections           
          6601(e)(2) and 6621(c).                                                     
          Petitioners filed objections to respondent's motions in                     
          which they cited Ohio Farm Bureau Federation v. Commissioner, 106           
          T.C. 222 (1996), and Northwestern Indiana Telephone Co. v.                  
          Commissioner, T.C. Memo. 1996-168, for the proposition that this            
          Court has the authority, by virtue of its jurisdiction to                   
          redetermine deficiencies in tax, to redetermine a corporation's             
          liability for interest under section 6621(c).  In the                       
          alternative, petitioners argued in their objections that this               
          Court has jurisdiction to redetermine such interest after payment           
          and within 1 year of the date on which the decision of the Court            
          becomes final, pursuant to section 7481(c).                                 
               During the course of the oral argument on respondent's                 
          motions, counsel for both parties acknowledged that the Court's             
          memorandum opinion in Northwestern Indiana Telephone Co. v.                 
          Commissioner, supra, had been modified (by Order dated April 17,            
          1996) to eliminate all references to section 6621(c).  The                  
          parties also acknowledged that, although Ohio Farm Bureau                   

          notice of deficiency is sent.                                               

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