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calculations indicate that, in addition to a $6,200 refund of
tax, respondent would owe that taxpayer $59,728 of interest as of
the close of calendar year 2005.
It is basic that accrued interest will vary depending upon
the amount owed, the time the amount has been owing, and the
rates at which the interest accrues. The parties differ not only
over the amount owed, that is, the amount of the deficiencies,
but also the time the deficiencies should be deemed to have been
outstanding (there does appear to be a consensus, with which the
Court agrees, that the applicable rates of interest are those
prescribed pursuant to section 6621 and set forth most recently
in Rev. Rul. 2005-62, 2005-38 I.R.B. 557, which adopts the tables
provided in Rev Proc. 95-17, 1995-1 C.B. 556).
Inasmuch as this Court is a court of limited jurisdiction,
we may exercise jurisdiction only to the extent expressly
authorized by statute. Sec. 7442; Judge v. Commissioner, 88 T.C.
1175, 1180-1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529
(1985). While this Court has jurisdiction to determine
deficiencies in tax pursuant to section 6214, it is well settled
that such jurisdiction generally does not extend to statutory
interest imposed under section 6601. See Bax v. Commissioner, 13
F.3d 54, 56-57 (2d Cir. 1993); Pen Coal Corp. v. Commissioner,
107 T.C. 249, 255 (1996); LTV Corp. v. Commissioner, 64 T.C. 589,
597 (1975); see also Betz v. Commissioner, 90 T.C. 816, 823
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