- 7 -
see also Dixon v. United States, 381 U.S. 68, 72-73 (1965);
McGuire v. Commissioner, 77 T.C. 765, 779-780 (1981).
Accordingly, we are left with no alternative but to sustain
respondent’s deficiency determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.7
7 In an action for redetermination of a deficiency, this
Court does not generally have jurisdiction over interest.
Accordingly, the decision that we shall enter will speak only to
petitioners’ liability for the $577 deficiency in income tax.
However, we note that at trial, counsel for respondent
acknowledged that interest on the deficiency will be abated by
respondent.
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