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6201(a), not section 6215. Brookes v. Commissioner, 108 T.C. 1,
9-10 (1997).12
We hold that we do not have jurisdiction under section
7481(c) to review petitioner’s motion to redetermine interest.
An appropriate order
will be entered.
12Whether the computational adjustments were in fact made
with respect to affected items requiring partner-level
determinations, as petitioner contends, is not a matter that we
can decide absent a proper jurisdictional basis for review. We
recognize that the import of our decision is that we are unable
to “reopen” a prior unified partnership proceeding under sec.
7481(c) and to redetermine interest attributable to a
computational adjustment deficiency. However, the conference
agreement with respect to the 1997 revision of sec. 7481(c)
states:
In clarifying the Tax Court’s jurisdiction over
interest determinations, the conferees do not intend to
limit any other remedies that taxpayers may currently
have with respect to such determinations, including in
particular refund proceedings relating solely to the
amount of interest due. [H. Conf. Rept. 105-220, at
733 (1997), 1997-4 C.B. (Vol. 2) 1457, 2203.]
For example, respondent suggests that the refund claim procedures
for challenging erroneous computational adjustments, sec.
6230(c), are the appropriate forum for challenging the
computational adjustments in this case.
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