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          change was intended.  Id.  We further observed that the language            
          in former section 274(e) expanding the Board's authority to                 
          determine whether "any penalty, additional amount or addition to            
          the tax should be assessed" was added by the Senate Finance                 
          Committee for the express purpose of allowing the Commissioner to           
          determine that a deficiency is attributable to fraud or                     
          negligence, after the issuance of a deficiency notice, but                  
          without requiring the Commissioner to issue a second notice of              
          deficiency to the taxpayer.  Id. at 1103-1104 (citing S. Rept.              
          52, 69th Cong., 1st Sess. (1926), 1939-1 C.B. (Part 2) 332, 353).           
          We stated that "the legislative history of section 6214(a)                  
          indicates that the provision was not designed to have the broad             
          meaning urged by the Commissioner."  Id. at 1104.                           
               We also pointed out in Bregin that the Commissioner was                
          given the authority under section 6201(a)(3) to recover amounts             
          due from a taxpayer's overstatement of withholding credits                  
          without issuing a notice of deficiency.  Under the circumstances,           
          we could find no indication that Congress intended section                  
          6214(a) to provide the Commissioner with an alternative method              
          for recovering on such a claim.  Id. at 1104-1105.                          
          Petitioners, like the Commissioner in Bregin, propose a                     
          broad interpretation of the term "additional amount" in section             
          6214(a) in an effort to persuade the Court to exercise                      
          jurisdiction over an item that otherwise does not satisfy the               
          statutory definition of a deficiency under section 6211(a).  In             

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