Tom I. Lincir and Diane C. Lincir - Page 7

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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) 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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