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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
6621(c).
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.
6211(a).
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