John Y. & Marion Robnett - Page 17




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          6601(a) and therefore subject to the same jurisdictional                    
          restrictions as regular interest prescribed by section 6601(a).             
          See Pen Coal Corp. v. Commissioner, supra at 255.                           
               Because the record does not indicate that petitioners have             
          paid the section 6621(c) tax-motivated interest assessed by                 
          respondent, this Court does not have jurisdiction to review its             
          assessment.  Based upon this holding, we do not reach the issue             
          of whether such interest was properly assessed in this case.                
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               





























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