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               The question of the scope of this Court's jurisdiction under           
          former section 6621(c) arose in White v. Commissioner, 95 T.C. at           
          212-214, involving a so-called affected items proceeding.  In               
          White, the Commissioner issued a notice of deficiency to the                
          taxpayers solely for additions to tax after the underlying tax              
          deficiency was assessed following the conclusion of partnership             
          level proceedings.  The taxpayers filed a petition contesting the           
          additions to tax as well as their liability for additional                  
          interest under former section 6621(c).  This prompted the                   
          Commissioner to file a motion to dismiss for lack of jurisdiction           
          as to the additional interest.                                              
               In granting the Commissioner's motion to dismiss in White,             
          we first held, based upon a combined reading of sections 6211(a),           
          6230(a), and 6601(e)(1), that interest computed at the increased            
          rate prescribed in former section 6621(c)(1) is not a deficiency            
          within the meaning of section 6211(a).  Consistent with this                
          holding, we rejected the taxpayers' argument that section                   
          6230(a)(2)(A)(i) provided statutory authority for this Court to             
          redetermine such interest.  Next, we analyzed former section                
          6621(c)(4) and concluded that our jurisdiction under that                   
          provision is limited to cases where the parties dispute a                   
          deficiency in tax imposed by subtitle A, and, specifically, to              
          determining whether a portion of such a deficiency constitutes a            
          substantial underpayment attributable to tax-motivated                      
          transactions.  In other words, Congress granted this Court                  

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Last modified: May 25, 2011