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interest on a deficiency until the deficiency is paid or
otherwise abated. We therefore conclude that petitioner is
liable for interest under section 6601.
With respect to redetermining assessments of interest
pursuant to section 6601, however, our jurisdiction is limited.
First, section 7481(c) provides that if within 1 year after a
decision of the Tax Court becomes final, the taxpayer files a
petition to redetermine interest, the Tax Court has overpayment
jurisdiction with regard to interest. See Med James, Inc. v.
Commissioner, 121 T.C. 147, 151 (2003). Second, section
6404(h)(1) provides the Tax Court with jurisdiction to review
whether the Commissioner’s refusal to abate interest under
section 6404 was an abuse of discretion.
In regard to redetermining the assessment of interest, we
find it significant that petitioner failed to submit a
computation demonstrating the basis for his allegation as
specifically directed by the Court in its December 15, 2005
Order. In light of his own noncompliance, petitioner has not in
good faith placed a triable issue in dispute. In the absence of
supporting facts that would show the assessed amounts are in
error, petitioner’s allegation fails to rise to the level of a
cognizable claim that would provide a basis for us to grant
relief. See Rule 331(b)(5).
Even if we were to broadly construe petitioner’s allegation
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