Pen Coal Corp. v. Commissioner
United States Tax Court
Ps filed petitions for redetermination contesting, inter alia, R's determination that Ps are liable for interest computed at the increased rate prescribed in sec. 6621(c), I.R.C., applicable to large corporate underpayments of tax.
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Ps filed petitions for redetermination contesting, inter alia, R's determination that Ps are liable for interest computed at the increased rate prescribed in sec. 6621(c), I.R.C., applicable to large corporate underpayments of tax. R filed motions to dismiss for lack of jurisdiction and to strike allegations relating to Ps' liability for interest under sec. 6621(c). Held: Sec. 6214(a) does not provide statutory authority for this Court to redetermine Ps' liability for interest computed at the increased rate prescribed in sec. 6621(c). Held, further, R's motions to dismiss for lack of…
1Opinion of the Court
OPINION
Ruwe, Judge:
This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Armen, Special Trial Judge:
These cases are before the Court on (1) respondent’s motion to dismiss for lack of jurisdiction and to strike as to interest due from the petitioner, filed in docket No. 23670-95; and (2) respondent’s motion to dismiss for lack of jurisdiction and to strike as to the…
2Cases cited10 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Judge v. CommissionerUnited States Tax Court · 1987
- White v. CommissionerUnited States Tax Court · 1990
- Alphonso Bax and Alice Corrine Bax, Deceased, and Alphonso L. Bax, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
5 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Sarrell v. Comm'rUnited States Tax Court · 2001
- Bankamerica Corp. v. CommissionerUnited States Tax Court · 1997
- Med James, Inc. v. Comm'rUnited States Tax Court · 2003
- Corbalis v. Comm'rUnited States Tax Court · 2014
- El v. CommissionerUnited States Tax Court · 2015
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