- 54 - concluded that we did not have jurisdiction under section 6230 to redetermine additional interest. White v. Commissioner, supra at 212-214. Petitioner is in the same procedural posture as the taxpayer in White, and our holding in White is controlling. Our affected item jurisdiction under section 6230(a)(2)(A)(i) does not include jurisdiction to redetermine whether petitioner is liable for additional interest. Id. 2. Section 6621(c)(4) Jurisdiction Section 6621(c)(4) provides that In the case of any proceeding in the Tax Court for a redetermination of deficiency, the Tax Court shall also have jurisdiction to determine the portion (if any) of such deficiency which is a substantial underpayment attributable to tax motivated transactions. The Tax Court, therefore, has jurisdiction in a deficiency proceeding to determine the portion of such deficiency that is a substantial underpayment attributable to tax-motivated transactions. The language “such deficiency” refers to the deficiency that the Court is redetermining. White v. Commissioner, supra at 216. In White, we also decided whether section 6621(c)(4) gave us jurisdiction to redetermine the taxpayer’s liability for additional interest. We held that it did not. Section 6621(c)(2) provides that a “substantial underpayment attributable to tax motivated transactions” means anyPage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
Last modified: May 25, 2011