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to redetermine a deficiency in tax generally does not extend to
statutory interest imposed under section 6601. See Bax v.
Commissioner, 13 F.3d 54, 56-57 (2d Cir. 1993), affg. an Order of
this Court; 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). Indeed, section 6601(e)(1) provides
that interest prescribed by section 6601 is treated as a tax
"except [for purposes of] subchapter B of chapter 63, relating to
deficiency procedures". Because the effect of the parenthetical
language of section 6601(e)(1) is to exclude interest from the
definition of a "tax" for purposes of section 6211(a), it follows
that such interest is not a deficiency. See White v.
Commissioner, 95 T.C. 209, 213 (1990). We are therefore
precluded in the context of a deficiency action from deciding
whether respondent properly determined the amount of interest
imposed under section 6601. But see sec. 7481(c) and Rule 261
regarding supplemental proceedings to redetermine interest on
deficiencies on taxes; cf. sec. 6404(i) and Rules 280-284
regarding actions for review of failure to abate interest.
Petitioner also contends that respondent erred in failing to
reduce the "deficiency" by the $750 remitted by petitioner. We
disagree.
The term "deficiency" is a technical term which is defined
by the Internal Revenue Code. See section 6211(a). As relevant
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