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Petitioners assert that, because the Court has jurisdiction
to redetermine their liability for section 6621(c) interest, the
Court also has jurisdiction to determine how such increased
interest is computed. Petitioners further assert that a plain
reading of the applicable provisions leads to the conclusion that
the amounts that they owe pursuant to section 6621(c), an item
that is tied directly to the rate of interest under section 6621,
will be substantially reduced when computed pursuant to the
interest-netting rule.
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. See sec. 7442; Judge v. Commissioner, 88 T.C. 1175,
1180-1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529
(1985). It is well settled that this Court's jurisdiction to
redetermine a deficiency in tax generally does not extend to
statutory interest imposed under section 6601. See Bax v.
3(...continued)
(3) within 1 year after the date the decision of
the Tax Court becomes final under subsection
(a), the taxpayer files a petition in the Tax
Court for a redetermination that the amount
of interest claimed by the Secretary exceeds
the amount of interest imposed by this title,
then the Tax Court may reopen the case solely to
determine whether the taxpayer has made an overpayment
of such interest and the amount of any such
overpayment. * * *
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Last modified: May 25, 2011