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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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