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disclose the relevant facts of that treatment, we uphold
respondent on this issue.
The third issue for decision is whether this Court has
jurisdiction to review the section 6621(c) tax-motivated interest
assessed by respondent. Section 6621(c), formerly section
6621(d)--as in effect for taxable years for which returns were
due prior to 1990, for interest accruing after 1984--provides an
increased rate of interest for substantial underpayments
attributable to tax-motivated transactions. This Court generally
lacks jurisdiction to redetermine interest prior to an entry of a
decision redetermining a deficiency. See sec. 7481(c) (as
currently in effect); Rule 261; Pen Coal Corp. v. Commissioner,
107 T.C. 249, 255 (1996). Furthermore, this Court generally does
not have jurisdiction to review respondent’s assessment of
section 6621(c) tax-motivated interest in affected item
proceedings, such as in the present case, even though the tax-
motivated interest is an affected item which requires a partner
level determination. See White v. Commissioner, 95 T.C. 209
(1990); Greene v. Commissioner, T.C. Memo. 1995-105. A narrow
exception to this rule applies if a taxpayer has paid the
assessed tax-motivated interest and subsequently invokes the
overpayment jurisdiction of this Court under section 6512(b).
See Barton v. Commissioner, 97 T.C. 548 (1991).
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