- 25 -
consideration of that issue for another day. Suffice it to say
that the mere possibility that our jurisdiction may be limited in
a proceeding under section 7481(c) to determine petitioners'
liability for interest pursuant to section 6621(c) does not
provide the requisite statutory basis for us to exercise
jurisdiction over that matter in these deficiency proceedings.
Conclusion
In order to reflect the foregoing,
Orders granting respondent's
Motions to Dismiss for Lack of
Jurisdiction and to Strike
will be issued.
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