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jurisdiction under section 6621(c)(4) to redetermine additional
interest.25
D. Conclusion
We have carefully considered all remaining arguments by the
parties for results contrary to those expressed herein and, to
the extent not discussed above, conclude that those arguments
are without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
25If petitioner had paid some or all of the additional
interest that was determined by respondent under sec. 6621,
petitioner would have had the opportunity to contest his
liability for such interest pursuant to the Court’s overpayment
jurisdiction. See sec. 6512(b); Barton v. Commissioner, 97 T.C.
548 (1991); Barlow v. Commissioner, T.C. Memo. 2000-339.
Petitioner does not contend that he paid any of the additional
interest.
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