Med James, Inc. - Page 10

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          interest (and penalties) related to the deficiency.  Petitioner’s           
          motion to redetermine interest was filed on March 17, 2003, which           
          date was within 1 year of the date the Court’s decision became              
          final.  Thus, petitioner has satisfied the first two                        
          jurisdictional prerequisites.                                               
               Section 6215 requires a petition filed by the taxpayer with            
          this Court and an amount redetermined as a deficiency by a                  
          decision of the Court which has become final.  ASA Investerings             
          Pship. v. Commissioner, supra at 426.  These requirements have              
          been met because a petition was filed to this Court and the Court           
          entered a decision, which has become final, redetermining an                
          amount as a deficiency.  The evidence in the record reflects that           
          respondent has assessed the deficiency and interest for the tax             
          year ended January 31, 1994.  Accordingly, we hold that the                 
          requirements of section 7481(c) have been met and we have                   
          jurisdiction to determine whether petitioner made an overpayment            
          of interest.                                                                
          II. Applicable Interest Rate                                                
               Interest on underpayments of tax is generally imposed at the           
          normal underpayment rate of the Federal short-term rate plus 3              
          percentage points.  Secs. 6601(a), 6621(a)(2).  Section 6621(c)             
          imposes an additional 2-percent interest rate, called hot                   
          interest, on large corporate underpayments.  In the present case,           
          if applicable, this additional interest would be imposed by                 






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