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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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