Tom I. Lincir and Diane C. Lincir - Page 6

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          Section 6621(c) Interest                                                      
               Respondent argues that the question whether the interest-                
          netting rule affects the computation of section 6621(c) interest              
          is not ripe for consideration in this deficiency proceeding.                  
          Citing the principle that the Court generally lacks jurisdiction              
          in a deficiency proceeding to redetermine interest, respondent                
          argues that the parties have not computed the amount of statutory             
          interest due from petitioners, and thus the parties are unable to             
          compute the amount of increased interest due under section                    
          6621(c).  Respondent contends that the legal question of the                  
          effect of section 6621(d) is a matter that may only be raised                 
          within the context of a supplemental proceeding brought pursuant              
          to section 7481(c).3                                                          

               3  Sec. 7481(c), enacted in the Technical and Miscellaneous              
          Revenue Act of 1988, Pub. L. 100-647, sec. 6246(a), 102 Stat.                 
          3342, 3751, confers jurisdiction on the Court to resolve disputes             
          over respondent's postdecision computation of statutory interest.             
          See note to Rule 261, 93 T.C. 1040-1041 (1989).  Sec. 7481(c)                 
          provides in pertinent part:                                                   
               SEC. 7481(c) Jurisdiction Over Interest                                  
               Determinations.--Notwithstanding subsection (a), if–                     
               (1) an assessment has been made by the Secretary                         
                    under section 6215 which includes interest as                       
                    imposed by this title,                                              
               (2) the taxpayer has paid the entire amount of                           
               the deficiency plus interest claimed by the Secretary,                   

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