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substantial underpayment attributable to tax motivated
transactions.
Respondent presumably determined that the underlying deficiency
in this case was a substantial underpayment attributable to a
tax-motivated transaction. This Court does not have jurisdiction
to review the underlying deficiency, however, because it was a
computational adjustment made pursuant to an adjustment to a
partnership item determined in a partnership proceeding. See
Saso v. Commissioner, 93 T.C. 730, 734 (1989). Thus, because the
underlying deficiency is not before this Court, section
6621(c)(4) cannot confer jurisdiction on this Court to determine
what portion of such underlying deficiency is attributable to a
tax-motivated transaction. Furthermore, although each addition
to tax at issue in this case is a “deficiency” within the meaning
of section 6621(c)(4), section 6621(c)(2) excludes additions to
tax from the definition of “substantial underpayment attributable
to tax motivated transactions,” thereby precluding review under
section 6621(c)(4). White v. Commissioner, supra at 216.
Petitioners further argue that this court has jurisdiction
over this matter because the amount assessed by respondent under
the authority of section 6621(c) is a penalty, not interest.
Tax-motivated interest is clearly interest, prescribed in the
same manner as all interest--under section 6601(a), at the rate
set forth in section 6621. Even if the interest could be
considered a “penalty”, it is nonetheless prescribed by section
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