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Petitioners have attempted to place in dispute their
liability for interest under section 6621(c) in an effort to have
the Court determine the correct "applicable date" for computing
such interest. Petitioners allege that they were not given a
meaningful opportunity for Appeals Office review and that the
applicable date should be from August 17, 1995, the date on which
the deficiency notices were mailed in these cases, rather than
the earlier dates determined by respondent.6
It is well settled that this Court is a court of limited
jurisdiction and that we may exercise jurisdiction only to the
extent expressly authorized by statute. Sec. 7442; Judge v.
Commissioner, 88 T.C. 1175, 1180-1181 (1987); Naftel v.
Commissioner, 85 T.C. 527, 529 (1985). It is equally well
settled that this Court's jurisdiction to redetermine a
deficiency in tax generally does not extend to statutory interest
imposed under section 6601. See Bax v. Commissioner, 13 F.3d 54,
56-57 (2d Cir. 1993), affg. an Order of this Court; LTV Corp. v.
Commissioner, 64 T.C. 589, 597 (1975); see also Asciutto v.
Commissioner, T.C. Memo. 1992-564, affd. 26 F.3d 108 (9th Cir.
1994). Indeed, section 6601(e)(1) expressly provides that
interest prescribed by section 6601 is treated as tax "except
[for purposes of] subchapter B of chapter 63, relating to
deficiency procedures". Because the effect of such language is
to exclude interest from the definition of a "tax" for purposes
6See supra note 4.
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