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because the determination of a taxpayer’s liability for such
interest may require findings of fact peculiar to the particular
taxpayer, namely, the amount of the taxpayer’s underpayment that
is attributable to a tax-motivated transaction. See N.C.F.
Energy Partners v. Commissioner, supra at 745-746. Because the
application of section 6621(c) turns on matters that are specific
to individual partners, it follows that such interest constitutes
an affected item that cannot be reviewed in a partnership level
proceeding. See Affiliated Equipment Leasing II v. Commissioner,
97 T.C. 575, 577-578 (1991); N.C.F. Energy Partners v.
Commissioner, supra at 745-746.
Ironically, however, a specific partner's liability for
additional interest under section 6621(c) normally cannot be
raised in an affected items proceeding. This rule, first
articulated in White v. Commissioner, supra, follows from a
combined reading of sections 6211(a), 6230(a), and 6601(e)(1),
which together provide that interest computed under the increased
rate under section 6621(c) is not a "deficiency" within the
meaning of section 6211. Because our authority in affected items
proceedings derives from our jurisdiction to redetermine a
deficiency under subchapter B of chapter 63, see sec. 6230(a)(2),
we generally have no authority to consider additional interest
under section 6621 in affected items proceedings. See Odend'hal
v. Commissioner, 95 T.C. 617 (1990). A narrow exception to this
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