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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.
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