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petitioner may raise this issue in this proceeding,11 we conclude
that he would not prevail on the merits.
Generally, interest on a Federal income tax liability begins
to accrue from the last date prescribed for payment of that tax
and continues to accrue, compounding daily, until payment is
made. Secs. 6601(a), 6622. Section 6601(g) further allows
respondent to assess and collect interest at any time during the
period within which the underlying tax may be collected. See
sec. 301.6601-1, Proced. & Admin. Regs. The manner of assessing
interest is the same as assessing tax; that is, interest is
assessed by recording the liability of the taxpayer in the office
of the Secretary in accordance with rules or regulations. Sec.
6203. Unlike the assessment procedure for income taxes, however,
a notice of deficiency is not required before assessing
interest.12 See sec. 6213(a). In sum, a taxpayer is liable for
11 Generally, the right to challenge the existence and
amount of underlying tax liability encompasses the right to
challenge the existence and amount of disputed interest thereon.
Urbano v. Commissioner, 122 T.C. 384, 389-390 (2004). The facts
in Urbano, however, are distinguishable from the present case.
In Urbano, the taxpayers did not receive a notice of deficiency
because they waived their right to contest the findings in Form
4549. Form 4549, however, did not include a finding with respect
to disputed interest. In their sec. 6320 hearing, the taxpayers
challenged their liability for sec. 6601 interest and claimed
interest abatement. Under the facts of that case, the Court held
that we had jurisdiction to redetermine interest.
12 As applicable herein, sec. 6213(a) applies to the
assessment of a deficiency in respect of any tax imposed by
subtitle A (income taxes).
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