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          increased rate prescribed in section 6621(c) on the ground that             
          such interest constitutes an "additional amount" within the                 
          meaning of section 6214(a).  In conjunction with the foregoing,             
          petitioners contend that this Court's narrow interpretation of              
          section 6214(a) in Bregin v. Commissioner, 74 T.C. 1097 (1980),             
          is erroneous.  Petitioners further contend that the lack of any             
          mention of this Court's jurisdiction in section 6621(c), despite            
          the presence of such a provision in former section 6621(c), is at           
          most a neutral factor to be taken into account in resolving                 
          congressional intent.  We disagree with petitioners' contentions.           
               In Bregin v. Commissioner, supra, the taxpayer filed a tax             
          return for 1974 on which he claimed a credit for taxes withheld             
          on his wages in excess of the amounts shown to have been withheld           
          on his Forms W-2.  The Commissioner overlooked the discrepancy              
          and allowed a refund to the taxpayer based on the withholding               
          credit reported on the taxpayer's return.  Later, the                       
          Commissioner issued a notice of deficiency to the taxpayer in               
          which the Commissioner determined that the taxpayer had received            
          unreported income in 1974.  The notice did not include any                  
          allegation that the taxpayer had claimed any excessive credit.              
          The taxpayer invoked this Court's jurisdiction by filing a                  
          petition for redetermination.                                               
          Shortly before trial, the Commissioner filed a motion for                   
          leave to amend answer to include an allegation that the taxpayer            
          had claimed an excessive withholding credit under section 31.               

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