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in regard to our jurisdiction thereover, will be helpful before
we discuss this matter further.
Former section 6621(c), originally codified as section
6621(d) and applicable with respect to interest accruing after
December 31, 1984, provided that interest payable under section
6601 will be computed at a rate equal to 120 percent of the
normal rate provided under section 6601 on any substantial
underpayment of tax attributable to a tax-motivated transaction.9
Former section 6621(c)(4) provided in pertinent part:
(4) Jurisdiction of Tax Court.--In the case of any
proceeding in the Tax Court for a redetermination of a
deficiency, the Tax Court shall also have jurisdiction
to determine the portion (if any) of such deficiency
which is a substantial underpayment attributable to tax
motivated transactions.
In short, former section 6621(c)(4) established a limited
exception to the general rule that this Court lacks jurisdiction
over statutory interest by providing that, in a proceeding for
redetermination of a deficiency, this Court has jurisdiction to
determine the portion (if any) of such a deficiency that is a
substantial underpayment attributable to tax-motivated
transactions.
9Sec. 6621(d) was added to the Internal Revenue Code by the
Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 144(a), 98
Stat. 494, 682. Sec. 6621(d) was redesignated sec. 6621(c) by
the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1511(c)(1)(A)-
(C), 100 Stat. 2085, 2744. Former sec. 6621(c) was repealed by
sec. 7721(b) of the Omnibus Budget Reconciliation Act of 1989,
Pub. L. 101-239, 103 Stat. 2106, 2399, effective with respect to
returns the due date for which is after Dec. 31, 1989.
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