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          misplaced; and (2) Congress simply did not intend for this Court            
          to exercise jurisdiction, at least in the context of a deficiency           
          proceeding, to redetermine a taxpayer's liability for interest              
          computed at the increased rate prescribed in present section                
               With regard to the first point, we note that if petitioners'           
          theory that section 6214(a) provides this Court with jurisdiction           
          to redetermine interest under section 6621(c) were correct, there           
          would have been no need for Congress to enact former section                
          6621(c)(4).11  Thus, in order to avoid an interpretation that               
          would render former section 6621(c)(4) redundant and superfluous,           
          it follows that petitioners' theory of jurisdiction is incorrect.           
               In addition to the foregoing, we believe that former section           
          6621(c)(4) reflects Congress' understanding of the need to                  
          specifically define this Court's jurisdiction with respect to               
          matters involving statutory interest in recognition of section              
          6601(e)(1), which serves to deny this Court jurisdiction over               
          such interest.  Against this background, we conclude that                   
          Congress would have expressly granted this Court jurisdiction to            
          redetermine interest computed at the increased rate prescribed by           
          present section 6621(c) if such had been the intent of Congress.            

               11Further, taking petitioners' theory to its logical                   
          conclusions, the issue might arise whether this Court has                   
          jurisdiction as to interest in general, notwithstanding the                 
          provisions of sec. 6601(e) or as to any item that would not                 
          otherwise satisfy the definition of a deficiency under sec.                 

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