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Section 7481(c)
Petitioners' initial objections to respondent's motions to
dismiss included an alternative argument that this Court has the
authority, by virtue of section 7481(c), to consider petitioners'
liability for interest computed at the increased rate prescribed
in section 6621(c).
Section 7481(c), codified by section 6246(a) of the
Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647,
102 Stat. 3342, 3751, serves to confer jurisdiction on this Court
to resolve disputes concerning respondent's post-decision
computation of statutory interest; i.e., to determine interest on
deficiencies that have been redetermined by this Court and
assessed under section 6215. See, e.g., Stauffacher v.
Commissioner, 97 T.C. 453 (1991); Note to Rule 261, 93 T.C. 821,
1040-1041 (1989).
Section 7481(c) provides in pertinent part as follows:
SEC. 7481(c). Jurisdiction Over Interest
Determinations.--Notwithstanding subsection (a), if--
(1) an assessment has been made by the
Secretary under section 6215 which includes
interest as imposed by this title,
(2) the taxpayer has paid the entire
amount of the deficiency plus interest
claimed by the Secretary, and
(3) within 1 year after the date the
decision of the Tax Court becomes final under
subsection (a), the taxpayer files a petition
in the Tax Court for a determination that the
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