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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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