- 53 -
See, e.g., Ewing v. Commissioner, 118 T.C. 494, 498 (2002). Our
jurisdiction to correct error in respondent’s interest
computations stems from section 6404(h)(2)(B), which provides
that rules similar to the rules of section 6512(b) apply for
purposes of section 6404(h). Supra note 12. Section 6512(b)
generally defines this Court’s jurisdiction with respect to
overpayments. See Winn-Dixie Stores, Inc. & Subs. v.
Commissioner, 110 T.C. 291, 294 (1998). Section 6512(b)
provides, inter alia, that if a taxpayer properly invokes our
overpayment jurisdiction under section 6512(b), then we have
jurisdiction to determine the amount of the taxpayer’s
overpayment. This jurisdiction under section 6512 also permits
us to redetermine a taxpayer’s statutory interest. Lincir v.
Commissioner, 115 T.C. 293, 298 (2000), affd. 32 Fed. Appx. 278
(9th Cir. 2002); see Zfass v. Commissioner, 118 F.3d 184, 192 n.9
(4th Cir. 1997), affg. T.C. Memo. 1996-167.
Petitioners have paid all the tax and interest assessed for
1979, 1981, 1982, and the parties agree that there is no
additional tax or interest that needs to be assessed.
Respondent’s concession that interest should be abated for the
period of time beginning on February 25, 1995, and ending on
April 25, 1995, results in an overpayment as to each of the years
in issue. Accordingly, pursuant to section 6404(h)(2)(B), we
have jurisdiction to determine the amount of petitioners’
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