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tax respondent determined for 1993. Petitioners dispute only
respondent’s assessment of the statutory interest related to the
tax. Respondent computed that interest under section 6601.
We generally lack jurisdiction over issues concerning
interest computed under section 6601. Med James, Inc. v.
Commissioner, 121 T.C. 147, 151 (2003). We have jurisdiction to
redetermine such interest primarily in two types of situations.
First, section 7481(c) authorizes the Court to redetermine an
overpayment of interest if a taxpayer timely petitions the Court
to do so. Id. at 151-153. Second, section 6404(h) authorizes
the Court to review for an abuse of discretion the Commissioner’s
refusal to abate interest under section 6404. Woodral v.
Commissioner, 112 T.C. 19, 22-23 (1999). As relevant herein,
section 6404(e)(1) gives the Commissioner the discretion to abate
the assessment of interest on: (1) Any deficiency attributable
to any error or delay by an officer or employee of the Internal
Revenue Service in performing a ministerial act, or (2) any
payment of any tax described in section 6212(a) to the extent
that any error or delay in payment is attributable to the
officer’s or employee’s being erroneous or dilatory in performing
a ministerial act.4 In addition, section 6404(a)(1) gives the
4 Sec. 6404(e) was amended by sec. 301(a)(1) and (2) of the
Taxpayer Bill of Rights 2, Pub. L. 104-168, 110 Stat. 1457
(1996), to permit the Commissioner to abate interest with respect
to an unreasonable error or delay resulting from managerial or
(continued...)
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