James G. & Katherine Bourekis - Page 8

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          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 set            

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