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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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