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additions to tax and other additional amounts (not labeled
"additions to tax") described in chapter 68.8
We likewise find petitioners' reliance on section 7806(b) to
be misplaced. Section 7806(b) provides that 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 title 26. In
Bregin, we did not draw an inference, implication, or presumption
of legislative construction by reason of the location or grouping
of any particular section or provision of the Internal Revenue
Code in interpreting section 6214(a). As explained above, we
merely looked to chapter 68, and the meaning given to the term
"additional amounts" therein, to aid in interpreting the same
term as it is found in section 6214(a). Simply stated, we see no
tension between the Court's analysis in Bregin and the
proscriptions of section 7806(b).
Former Section 6621(c)
Contrary to petitioners' contention, we also find former
section 6621(c) and the case law interpreting that section to be
relevant in resolving the jurisdictional issue presented by
respondent's motions. A brief review of the provisions of former
section 6621(c), as well as the case law developed by this Court
8We observe that the accuracy-related penalty imposed by
current sec. 6662 and the fraud penalty imposed by current sec.
6663 are both penalties and not additions to tax.
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