Hallmark Cards, Incorporated and Subsidiaries - Page 7

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          section 6215.  Because our decision in this case did not                    
          determine any deficiency for 1987, no deficiency was assessed               
          under section 6215, and therefore, petitioner argues, the Court             
          may not have jurisdiction under the earlier version of section              
          7481(c).                                                                    
               As indicated, the amendment has an effective date of                   
          August 5, 1997.  Unlike some statutory amendments, the effective            
          date is not tied to a specific event.3  Although the decision in            
          this case became final under section 7481(a) before the effective           
          date, the motion to redetermine interest was filed after the                
          effective date.  Thus, at the time of filing the motion to                  
          redetermine interest, the Court's jurisdiction undoubtedly                  
          extended to interest where the Court's decision on its face has             
          determined only an overpayment, as is the case herein.                      
               Aside from the effective date issue, we do not share                   
          petitioner's concern as to our jurisdiction because no deficiency           
          was determined by this Court and assessed pursuant to section               
          6215 as provided in section 7481(c)(1) as it existed prior to the           
          amendment.                                                                  
               Section 6215 provides in pertinent part:                               


               3  Cf., e.g., Technical and Miscellaneous Revenue Act of               
          1988 (TAMRA), Pub. L. 100-647, sec. 6246, 102 Stat. 3751                    
          (jurisdiction to review interest assessed on deficiency                     
          determined by the Tax Court effective with assessments made after           
          date of enactment); TAMRA, sec. 6247, 102 Stat. 3751                        
          (jurisdiction to reopen estate tax cases to determine deduction             
          for interest paid on installments of taxes effective for cases              
          for which the decision is not final on date of enactment).                  




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