Tom I. Lincir and Diane C. Lincir - Page 10

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               which is a substantial underpayment attributable to tax                  
               motivated transactions.                                                  
          In sum, section 6621(c)(4) establishes a limited exception to the             
          general rule that this Court lacks jurisdiction over statutory                
          interest by providing that, in a proceeding for redetermination               
          of a deficiency, this Court has jurisdiction to determine the                 
          portion (if any) of such a deficiency that is a substantial                   
          underpayment attributable to a tax-motivated transaction.                     
               Based upon the plain language of section 6621(c)(4), we                  
          conclude that Congress limited the Court's jurisdiction in a                  
          deficiency proceeding to determining the portion of a deficiency              
          that will be subject to increased interest under section 6621(c).             
          In this connection, we conclude that Congress did not intend for              
          the Court to compute or otherwise instruct respondent how to                  
          compute section 6621(c) interest in the context of a deficiency               
          Section 6653(a)(2)                                                            
               Contrary to respondent's argument with respect to section                
          6621(c), respondent asserts that the Court can reach the question             
          regarding the effect of section 6621(d) on the computation of the             
          addition to tax under section 6653(a)(2).  Respondent maintains,              

               5  Although respondent contends that petitioners will be                 
          able to raise the question of the impact of sec. 6621(d) on the               
          computation of increased interest under sec. 6621(c) pursuant to              
          a supplemental proceeding brought under sec. 7481(c), the scope               
          of the Court's jurisdiction in a sec. 7481(c) proceeding is not               
          properly before the Court at this time, and we express no opinion             
          on the point.                                                                 

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