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Commissioner, 13 F.3d 54, 56-57 (2d Cir. 1993), affg. an Order of
this Court; LTV Corp. v. Commissioner, 64 T.C. 589, 597 (1975);
see also Asciutto v. Commissioner, T.C. Memo. 1992-564, affd. 26
F.3d 108 (9th Cir. 1994). In particular, section 6601(e)(1)
provides that interest prescribed by section 6601 is treated as
tax "except [for purposes of] subchapter B of chapter 63,
relating to deficiency procedures”. Because the effect of such
language is to exclude interest from the definition of a "tax"
for purposes of section 6211(a), it follows that such interest
does not constitute a deficiency within the meaning of that
provision. See Pen Coal Corp. v. Commissioner, 107 T.C. 249, 255
(1996); White v. Commissioner, 95 T.C. 209, 213 (1990). For this
reason, the Court's decision documents normally will not include
a reference to a taxpayer's liability for statutory interest.
See Thomas v. Commissioner, T.C. Memo. 1994-291.
Consistent with section 6601(e), the Court does have
jurisdiction to redetermine statutory interest where a taxpayer
has properly invoked the Court's overpayment jurisdiction
pursuant to section 6512. See Barton v. Commissioner, 97 T.C.
548, 554-555 (1991). In Winn-Dixie Stores, Inc. & Subs. v.
Commissioner, 110 T.C. 291 (1998), we held that the Court had
jurisdiction under section 6512 to review the taxpayers' claim
that they had overpaid statutory interest for the years in issue
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