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of section 6211(a), it follows that such interest is not a
deficiency. See White v. Commissioner, 95 T.C. 209, 213 (1990).
Respondent moves to dismiss and to strike the allegations in
the petitions insofar as they pertain to section 6621(c) on the
grounds that (1) such interest does not fall within the
definition of a deficiency under section 6211(a), and (2) there
is otherwise no specific grant of statutory authority for this
Court to redetermine a taxpayer's liability for such interest.
Petitioners acknowledge the general limitations respecting
this Court's jurisdiction as to statutory interest.
Nevertheless, petitioners contend that section 6214(a) vests this
Court with jurisdiction to redetermine interest computed at the
increased rate prescribed in section 6621(c)(1).
Section 6214(a)
Section 6214(a) provides in pertinent part:
SEC. 6214(a). Jurisdiction as to Increase of
Deficiency, Additional Amounts, or Additions to the
Tax.--Except as provided by section 7463, the Tax Court
shall have jurisdiction to redetermine the correct
amount of the deficiency even if the amount so
redetermined is greater than the amount of the
deficiency, notice of which has been mailed to the
taxpayer, and to determine whether any additional
amount, or any addition to the tax should be assessed,
if claim therefor is asserted by the Secretary at or
before the hearing or a rehearing. [Emphasis added.]
Specifically, petitioners contend that section 6214(a) provides
this Court with authority to redetermine interest computed at the
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