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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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