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taxpayer was liable for the addition to tax for late payment
under section 6651(a)(2) even though we otherwise had
jurisdiction to redetermine the taxpayer’s liability for estate
tax. Congress reversed that holding by inserting the word “any”
in section 6214(a) as follows:
SEC. 6214(a). Jurisdiction as to Increase of
Deficiency, Additional Amounts, or Additions to the
Tax.--Except as provided by section 7463 [small case
procedures], the Tax Court shall have jurisdiction to
redetermine the correct amount of the deficiency even
if the amount so redetermined is greater than the
amount of the deficiency, notice of which has been
mailed to the taxpayer, and to determine whether any
additional amount, or any addition to the tax should be
assessed, if claim therefor is asserted by the
Secretary at or before the hearing or a rehearing.
[Emphasis added.]
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1554(a), 100 Stat.
2754. The conference agreement which accompanied enactment of
the 1986 amendment states, “The bill provides that the Tax Court
has jurisdiction over this addition to tax for failure to pay an
amount shown on the return where the Tax Court already has
jurisdiction to redetermine a deficiency in tax with respect to
that return.” S. Rept. 99-313, at 200 (1986), 1986-3 C.B. (Vol.
3) 1, 200; H. Conf. Rept. 99-841, at II-804 (1986), 1986-3 C.B.
(Vol. 4) 1, 804.
The Tax Court generally has jurisdiction over income, gift,
and estate tax cases for purposes of section 6330(d)(1)(A)
because we have deficiency jurisdiction relating to those taxes.
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Last modified: May 25, 2011