[an error occurred while processing this directive] Legal Research - Lawyer, Attorney, Law Firm, Paralegal


                                       - 18 -                                         
          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                      

               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  Former sec. 6621(c) was repealed by             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.                      

Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  Next

Last modified: May 25, 2011