William R. and Betty O. Bass - Page 14

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          6621(c).  The increased rate of interest under section 6621(c) is           
          120 percent of the statutory rate imposed on underpayments under            
          section 6601 if the underpayment exceeds $1,000 and is                      
          attributable to a tax-motivated transaction (as defined in                  
          section 6621(c)(3)).  The increased interest is effective only              
          with respect to interest accruing after December 31, 1984,                  
          notwithstanding that the transaction was entered into before that           
          date.  Solowiejczyk v. Commissioner, 85 T.C. 552 (1985), affd.              
          per curiam without published opinion 795 F.2d 1005 (2d Cir.                 
               This Court generally does not have jurisdiction to review              
          assessment of section 6621(c) tax-motivated interest in affected            
          item proceedings, even though the tax-motivated interest is an              
          affected item that requires a partner-level determination.  See             
          White v. Commissioner, 95 T.C. 209 (1990); Korchak v.                       
          Commissioner, T.C. Memo. 2005-244; see also Ertz v. Commissioner,           
          T.C. Memo. 2007-15.  A narrow exception to this rule applies if a           
          taxpayer has paid the assessed tax-motivated interest and                   
          subsequently invokes the overpayment jurisdiction of this Court             
          under section 6512(b).  See Barton v. Commissioner, 97 T.C. 548             
          (1991).  Petitioners do not claim that they have paid the                   

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