- 8 - that respondent did not determine, and does not assert, that petitioners are liable for additions to tax or penalties for 1981. Consequently, we shall grant respondent's motion to dismiss for lack of jurisdiction and to strike insofar as respondent moves to dismiss and strike allegations in the petition contesting additions to tax and penalties. 2. Jurisdiction--Statutory Interest Respondent also moves to dismiss for lack of jurisdiction and to strike allegations in the petition contesting statutory interest. The Court's jurisdiction to redetermine a tax deficiency generally does not extend to statutory interest imposed under section 6601. See 508 Clinton St. Corp. v. Commissioner, 89 T.C. 352, 354-355 (1987); LTV Corp. v. Commissioner, 64 T.C. 589, 597 (1975); see also Asciutto v. Commissioner, T.C. Memo. 1992-564, affd. 26 F.3d 108 (9th Cir. 1994). Outside of the Court's normal deficiency jurisdiction, however, section 6404(g) authorizes the Court to review the Commissioner's denial of a taxpayer's request to abate an assessment of statutory interest. See White v. Commissioner, 109 T.C. 96 (1997); Banat v. Commissioner, 109 T.C. 92 (1997). Petitioners rely upon section 6404(g) as the basis for the Court's jurisdiction in this case. Before proceeding with our analysis, we briefly review the Commissioner's authority to abate assessments of interest as setPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011