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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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