- 53 - 6621(c) as a sanction against the IRS for its district counsel’s misconduct in the trial of the test cases. The Court’s sanction was based on its finding that the IRS’ misconduct in the trial of the test cases had caused a substantial delay in resolution of the cases. Id. In the current case, there are no time-sensitive additions to tax or increased interest at issue. A change in the tax liability of a partner to reflect properly the treatment of a partnership item under subchapter C is made through a computational adjustment. See sec. 6231(a)(6). A computational adjustment includes any interest due with respect to any underpayment attributable to adjustments to reflect properly the treatment of partnership items. See sec. 301.6231(a)(6)-1T(b), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6790, 6791 (March 5, 1987). Such interest, however, is not a partnership item. See sec. 301.6231(a)(3)-1, Proced. & Admin. Regs. We have no jurisdiction in a partnership proceeding to abate interest. See sec. 6226(f). In certain cases, Congress has provided for the abatement of interest. See sec. 6404(i) (establishing jurisdiction in Tax Court to review denials of requests to abate interest in certain cases). The prerequisites of section 6404(i) have not here been met. Therefore, we shall deny the motion in its entirety. An appropriate order will be issued.Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53
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