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See secs. 6211(a), 6213(a), 6214(a); Landry v. Commissioner, 116
T.C. 60, 62 (2001); Katz v. Commissioner, 115 T.C. 329, 339
(2000); Van Es v. Commissioner, supra at 328; Goza v.
Commissioner, 114 T.C. 176, 182 (2000). We also have
jurisdiction “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.” Sec. 6214(a). Thus, just as we generally have
jurisdiction to decide income, gift, and estate tax cases, we
generally have jurisdiction over additions to tax for failure to
pay those taxes for purposes of section 6330(d)(1)(A).
Following the 1986 amendment to section 6214(a), we have
frequently exercised jurisdiction over the addition to tax under
section 6651(a)(2) when it has been asserted in a deficiency
case. See, e.g., Lee Engg. Supply Co. v. Commissioner, 101 T.C.
189, 196 n.5 (1993); Estate of La Meres v. Commissioner, 98 T.C.
294, 324-325 (1992); Bank of the West v. Commissioner, 93 T.C.
462, 472-474 (1989); Judge v. Commissioner, 88 T.C. 1175, 1187
(1987). In contrast, apart from an affected items proceeding,
section 6665(b) provides that we lack deficiency jurisdiction
over an addition to tax under section 6651(a) if no deficiency
was determined. See Estate of Forgey v. Commissioner, 115 T.C.
142, 146-147 (2000); Newby’s Plastering, Inc. v. Commissioner,
T.C. Memo. 1998-320. However, our holdings in those cases do not
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