- 17 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011