Med James, Inc. - Page 8

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          address this issue, we explain this Court’s jurisdiction to                 
          redetermine interest.5                                                      
          I.   Jurisdiction                                                           
               Generally, this Court lacks jurisdiction over issues                   
          involving interest.  Bax v. Commissioner, 13 F.3d 54, 56 (2d Cir.           
          1993); ASA Investerings Pship. v. Commissioner, 118 T.C. 423, 424           
          (2002); LTV Corp. v. Commissioner, 64 T.C. 589, 597 (1975).                 
          However, we do have jurisdiction to redetermine interest in                 
          certain limited circumstances.  Section 7481(c) provides:                   
                    SEC. 7481(c).  Jurisdiction Over Interest                         
               Determinations.--                                                      
                    (1) In General.–-Notwithstanding subsection (a),                  
               if, within 1 year after the date the decision of the                   
               Tax Court becomes final under subsection (a) in a case                 
               to which this subsection applies, the taxpayer files a                 
               motion in the Tax Court for a redetermination of the                   
               amount of interest involved, then the Tax Court may                    
               reopen the case solely to determine whether the                        
               taxpayer has made an overpayment of such interest or                   
               the Secretary has made an underpayment of such interest                
               and the amount thereof.                                                
                    (2) Cases to which this subsection applies.–- This                
               subsection shall apply where–-                                         
                         (A)(i) an assessment has been made by the                    
                    Secretary under section 6215 which includes interest              
                    as imposed by this title, and                                     
                         (ii) the taxpayer has paid the entire                        


               5In Pen Coal Corp. v. Commissioner, 107 T.C. 249, 254                  
          (1996), we held that we lacked jurisdiction to redetermine a                
          taxpayer’s liability for hot interest in deficiency proceedings.            
          We explicitly left for another day whether we have jurisdiction             
          to determine liability for hot interest in a supplemental                   
          proceeding commenced pursuant to sec. 7481(c) and Rule 261.  Id.            




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