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amount of tax previously assessed over any rebates. White v.
Commissioner, supra at 213.
In White, a case involving substantially the same
procedural facts as this case,23 we considered whether additional
interest is a “deficiency” within the meaning of section
6211(a). We held that it was not and that, therefore, we did
not have jurisdiction under section 6230(a)(2)(A)(i) to
redetermine additional interest. We explained that section
6601(e)(1), which provides generally that any reference in the
Code to any tax “shall be deemed also to refer to interest”,
excludes subchapter B of chapter 63 from that general rule.
Consequently, references to tax in the definition of deficiency
contained in section 6211(a) do not include interest. Because
our affected item jurisdiction under section 6230 is limited to
“a deficiency attributable to affected items which require
partner level determinations” and because additional interest is
not a deficiency within the meaning of section 6211(a), we
23In White v. Commissioner, 95 T.C. 209, 210 (1990), the
Commissioner issued an FPAA to the tax matters partner of a
partnership determining adjustments to a partnership’s return.
The taxpayers received a copy of the FPAA from the Commissioner
as notice partners, and neither the tax matters partner nor the
notice partners filed a petition disputing the FPAA. Id.
Thereafter, the Commissioner assessed the deficiency in tax
resulting from the partnership adjustments against the taxpayers
as a computational adjustment. Id. By a subsequent statutory
notice of deficiency, the Commissioner determined that the
taxpayers were liable for additional interest under section
6621(c), as well as additions to tax under secs. 6653(a)(1) and
(2) and 6659, and the taxpayers disputed the determination. Id.
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