Ernest I. Korchak - Page 54

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          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 any                       





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