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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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Last modified: May 25, 2011