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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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