Robert Ho - Page 20

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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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