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furtherance of their position, petitioners assert that the
Court's more restrictive interpretation of section 6214(a) in
Bregin is erroneous on the grounds that (1) the Court's
interpretation impermissibly renders the term "additional amount"
a mere redundancy; and (2) the Court violated section 7806(b) by
relying on the use of the term "additional amounts" in chapter 68
in interpreting the term "additional amount" in section 6214(a).7
We disagree with petitioners' assertion that this Court's
interpretation of section 6214(a) in Bregin v. Commissioner, 74
T.C. 1097 (1980), renders the term "additional amount" a mere
redundancy. As our detailed analysis of section 6214(a) and its
legislative history in Bregin amply demonstrates, Congress used
the phrase "any additional amount, or any addition to the tax" in
section 6214(a) to ensure an understanding that this Court's
jurisdiction encompasses items that are to be assessed,
collected, and paid in the same manner as taxes, including the
7Sec. 7806(b) provides in pertinent part:
SEC. 7806(b). Arrangement and Classification.--No
inference, implication, or presumption of legislative
construction shall be drawn or made by reason of the
location or grouping of any particular section or
provision or portion of this title, nor shall any table
of contents, table of cross references, or similar
outline, analysis, or descriptive matter relating to
the contents of this title be given any legal effect.
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