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          Federation v. Commissioner, supra, includes references to section           
          6621(c), the Court did not address in that case the                         
          Commissioner's determination that the taxpayer was liable for the           
          increased rate of interest applicable to large corporate                    
          underpayments of tax.  Id. at 223, 236 n.9.  In addition, counsel           
          for petitioners conceded that the Court lacks jurisdiction as to            
          petitioners' liability for interest under section 6601(e)(2).               
          And, based on respondent's concession that no notice of                     
          deficiency was issued to Pen Holdings for 1989, counsel for                 
          petitioners also conceded that insofar as Pen Holdings is                   
          concerned, the Court lacks jurisdiction as to the taxable year              
               Following the hearing on respondent's motions, both parties            
          filed additional memoranda with the Court.                                  


               The issue for decision in these cases is whether this Court            
          has jurisdiction to redetermine petitioners' liability for                  
          interest computed at the increased rate prescribed by section               
          6621(c) on large corporate underpayments of tax.  As explained in           
          greater detail below, we conclude that we lack jurisdiction to              
          redetermine such interest in these deficiency proceedings.  We              
          leave for another day whether we have jurisdiction to determine             

               5Both parties recognized that the Court may consider Pen               
          Holdings' 1989 taxable year in determining its correct tax                  
          liability for the years in issue.  Sec. 6214(b).                            

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