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post-decision computation of statutory interest; i.e., to
redetermine interest on deficiencies found by the Court and
assessed under section 6215.3 See note to Rule 261, 93 T.C. 821,
1040-1041 (1989); see also Stauffacher v. Commissioner, 97 T.C.
453 (1991). In addition, the Court is authorized pursuant to
section 6404(g) to review the Commissioner's denial of a
taxpayer's request for abatement of statutory interest.4 See
3 Sec. 7481(c), codified under sec. 6246(a) of the
Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647,
102 Stat. 3342, 3751, provides in pertinent part:
(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
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. * * *
4 Sec. 6404(g), codified under sec. 302(a) of the
Taxpayer Bill of Rights 2 (TBOR 2), Pub. L. 104-168, 110 Stat.
1452, 1457 (1996), provides in pertinent part as follows:
(continued...)
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