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Although recognizing that the alleged excessive credit did not
fall within the definition of a deficiency under section 6211(a),
the Commissioner argued that the Court had jurisdiction over the
issue on the ground that it constituted an "additional amount"
within the meaning of section 6214(a).
Upon review of the matter, we rejected the Commissioner's
argument for several reasons. First, we looked to chapter 68
entitled "Additions to the Tax, Additional Amounts, and
Assessable Penalties", for guidance as to the meaning of the term
"additional amount" as used in section 6214(a). In light of the
similarity between the language used in section 6214(a) and the
various provisions included under chapter 68, we concluded that
the term "additional amount" as used in section 6214(a) was meant
to refer to one of the assessable civil penalties described in
chapter 68. Bregin v. Commissioner, supra at 1102-1103.
Next, we examined the plain language of section 6214(a) and
its predecessors and reviewed the legislative history of such
section. We noted that section 6214(a) originated as section
274(e) of the Revenue Act of 1926, ch. 27, 44 Stat. 56, which
authorized this Court's predecessor, the Board of Tax Appeals, to
determine "whether any penalty, additional amount or addition to
the tax should be assessed." Bregin v. Commissioner, supra at
1103. Although the term "penalty" was later omitted when section
6214(a) was enacted as part of the Internal Revenue Code of 1954,
we observed that the committee reports declared that no material
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