ORDER
On September 25, 2006, the Court filed its Memorandum Findings of Fact and Opinion in the above-docketed case. In the Opinion, the Court found that it did not have jurisdiction to determine whether petitioner was liable for additional interest under I.R.C. Sec. 6621(c). However, the issue of whether or not the Court has jurisdiction to make such determination was not addressed by the parties. Upon further consideration and for cause, it is
ORDERED...
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