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limited authority to determine only the portion of a deficiency
in tax that is subject to interest computed at the increased rate
prescribed in former section 6621(c)(1). Because the only items
in dispute in White concerned additions to tax, the underlying
deficiency in tax having been previously assessed as a
computational adjustment pursuant to section 6230(a)(1), we held
that former section 6621(c)(4) did not provide this Court with
jurisdiction to redetermine the taxpayers' liability for
increased interest under former section 6621(c).10 Accord
Odend'Hal v. Commissioner, 95 T.C. 617 (1990) (where addition to
tax was sole item in dispute, this Court lacks jurisdiction to
redetermine interest computed at the increased rate prescribed in
former section 6621(c)(1)); cf. Barton v. Commissioner, 97 T.C.
548 (1991) (this Court has jurisdiction to redetermine additional
interest computed at the increased rate prescribed in former
section 6621(c)(1) pursuant to this Court's jurisdiction to
determine an overpayment under section 6512(b)(1)).
Although the specific subject matter of present section
6621(c) regarding corporate underpayments is different from that
of former section 6621(c) regarding substantial understatements
attributable to tax-motivated transactions, the operative
principle common to both provisions is the imposition of
10In concluding our opinion in White v. Commissioner, 95
T.C. 209, 217 (1990), we expressly suggested that congressional
action would be needed to fill the jurisdictional gap identified
in that case.
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