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statutory interest at an increased rate. Given the commonality
of purpose of the two provisions, it is wholly appropriate to
draw a negative inference from the fact that Congress expressly
granted this Court jurisdiction in former section 6621(c)(4) but
failed to do the same in present section 6621(c). In this
regard, a brief recapitulation of the various elements of our
analysis will buttress the point and expose the inherent weakness
in petitioners' position.
As previously discussed, this Court's jurisdiction to
redetermine a deficiency in tax generally does not extend to
statutory interest imposed under section 6601. Significantly,
section 6601(e)(1) provides that the deficiency procedures set
forth in subchapter B of chapter 63 are not applicable to
interest imposed under section 6601. In addition to these
principles, we have discussed this Court's opinion in Bregin v.
Commissioner, 74 T.C. 1097 (1980), where we held that the term
"additional amount" in section 6214(a) is limited to the
assessable civil penalties described in chapter 68. These
factors alone are adequate to overcome petitioners' assertion
that section 6214(a) provides a jurisdictional basis for this
Court to redetermine interest computed at the increased rate
prescribed in present section 6621(c).
Moreover, when Congress' enactment of former section
6621(c)(4) is also taken into account, the result is overwhelming
confirmation that (1) petitioners' reliance on section 6214(a) is
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