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                                       - 24 -                                         
                    amount of interest claimed by the Secretary                       
                    exceeds the amount of interest imposed by                         
                    this title,                                                       
               then the Tax Court may reopen the case solely to                       
               determine whether the taxpayer has made an overpayment                 
               of such interest and the amount of any such                            
               overpayment. * * *                                                     

               Notably, petitioners abandoned their alternative position in           
          the memoranda that they filed after the hearing in these cases.             
          Petitioners now assert that the question regarding the                      
          "applicable date" for computing interest at the increased rate              
          prescribed in section 6621(c) is not an issue the resolution of             
          which falls within this Court's jurisdiction under section                  
          7481(c).  Petitioners further assert that if this Court also                
          lacks jurisdiction to redetermine their liability for such                  
          interest in these deficiency proceedings, then they would be left           
          without a remedy in this Court.12                                           
               Consistent with the plain language of section 7481(c), it is           
          evident that the proceeding contemplated by such section may only           
          be brought after this Court's decision regarding the underlying             
          deficiency is final and the taxpayer has paid the interest in               
          dispute.  See Asciutto v. Commissioner, T.C. Memo. 1992-564,                
          affd. 26 F.3d 108 (9th Cir. 1994).  Accordingly, the scope of               
          this Court's jurisdiction under section 7481(c) is not a matter             
          that is properly before us at this time, and we therefore leave             

               12Petitioners do not assert that they would be without a               
          remedy in some other court.                                                 

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