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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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