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4. In effect, the aggregate amount of each type of
interest cannot be computed without considering all of the
transactions that were booked to the account and without
also considering all of the interest, whether overpayment
or underpayment, that was previously computed and combined
with earlier account balances.
As can be seen from the above, in order to compute the
aggregate amount of underpayment interest, it is necessary
for the Tax Court to review the same transactions, and
interest thereon, as involved in the computation of
overpayment interest. Thus, it would be impossible for
the Court to exercise overpayment jurisdiction with respect
to underpayment interest, unless the Court also had
jurisdiction over overpayment interest. For the same
reason, it would be impossible for a U.S. District Court
or the Court of Federal Claims to exercise general claims
jurisdiction over overpayment interest without considering
all of the transactions booked to petitioner’s account,
including transactions that are at issue in the Tax Court
case and the amount of underpayment interest charged to the
account.
As noted above, respondent concedes, on the basis of
Estate of Baumgardner v. Commissioner, 85 T.C. 445 (1985),
that our jurisdiction to determine an overpayment under
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