118 T.C. 423">*424 (OPINION

RUWE, Judge: On October 3, 2001, petitioner, AlliedSignal, Inc., filed a motion to redetermine interest under section 7481(c) and Rule 261. ¹ Petitioner claims to have overpaid deficiency interest in the following amounts and for the following tax years:

   Tax Year         Interest

   ________         ________

    1988          $ 415,714

    19892002 U.S. Tax Ct. LEXIS 26">*28          2,658,117

    1990          17,564,033

    1991              0

    1992          3,743,091

    1993           178,469

    1994          1,766,896

    1995          6,347,788

Respondent filed a notice of objection in which he moves to dismiss petitioner's motion for lack of jurisdiction. Respondent argues that we lack jurisdiction to redetermine petitioner's interest because no assessment has been made under section 6215. We agree and hold that we lack jurisdiction to redetermine petitioner's interest. ²

Generally, this Court does not have jurisdiction over issues involving interest. Bax v. Commissioner, 13 F.3d 54, 56 (2d Cir. 1993),2002 U.S. Tax Ct. LEXIS 26">*29 affg. an unpublished order of this Court; Standard Oil Co. v. McMahon, 244 F.2d 11, 13 (2d Cir. 1957). However, Congress has provided the Tax Court with jurisdiction to redetermine interest in certain limited circumstances. Section 7481(c) provides:

     SEC. 7481(c). Jurisdiction Over Interest Determinations. --

        (1) In general. -- Notwithstanding subsection (a), if,

     within 1 year after the date the decision of the Tax Court

     becomes final under subsection (a) in a case to which this

     subsection applies, the taxpayer files a motion in the Tax

     Court for a redetermination of the amount of interest

     involved, then the Tax Court may reopen the case solely to

     determine whether the taxpayer has made an overpayment of

     such interest or the Secretary has made an underpayment of

     such interest and the amount thereof.

        118 T.C. 423">*425 (2) Cases to which this subsection applies. -- This

     subsection shall apply where --

          (A)(i) an assessment has been made by the

2002 U.S. Tax Ct. LEXIS 26">*30         Secretary under section 6215 which includes interest

        as imposed by this title, and

          (ii) the taxpayer has paid the entire amount of

        the deficiency plus interest claimed by the Secretary,

        and

        (B) the Tax Court finds under section 6512(b) that the

     taxpayer has made an overpayment.

     (3) Special rules. -- If the Tax Court determines under

   this subsection that the taxpayer has made an overpayment of

   interest or that the Secretary has made an underpayment of

   interest, then that determination shall be treated under section

   6512(b)(1) as a determination of an overpayment of tax. An order

   of the Tax Court redetermining interest, when entered upon the

   records of the court, shall be reviewable in the same manner as

   a decision of the Tax Court.[³]

2002 U.S. Tax Ct. LEXIS 26">*31 We have jurisdiction to redetermine interest under section 7481(c) where: (1) The entire amount of the deficiency plus the entire amount claimed by the Commissioner as interest on the deficiency has been paid; (2) a timely motion to redetermine interest has been filed; and (3) an assessment has been made by the Commissioner under section 6215 which includes interest. See, e.g., Rule 261; Bankamerica Corp. v. Commissioner, 109 T.C. 1">109 T.C. 1, 109 T.C. 1">6-7 (1997); Asciutto v. Commissioner, T.C. Memo. 1992-564, affd. 26 F.3d 108 (9th Cir. 1994). ⁴

2002 U.S. Tax Ct. LEXIS 26">*32 Petitioner bases his motion to redetermine interest on our prior decision in this case. See ASA Investerings Pship. v. Commissioner, T.C. Memo. 1998-305, affd. 201 F.3d 505 (D.C. Cir. 2000). Our prior decision was affirmed by the Court of Appeals for the District of Columbia Circuit, and the U. S. Supreme Court denied certiorari on October 2, 2000, 118 T.C. 423">*426 531 U.S. 871 (2000). Our decision became final on October 2, 2000. Sec. 7481(a)(2)(B). Petitioner mailed its motion to redetermine interest on October 1, 2001; thus, the motion was timely. Sec. 7481(c)(1); Rule 261(a)(2). Petitioner claims, and respondent does not dispute, that it has paid the entire amount of the deficiency plus interest. Accordingly, the only issue in the instant case is whether respondent has assessed a deficiency and interest under section 6215.

Our jurisdiction over the issues decided in ASA Investerings Pship. v. Commissioner, supra, was predicated on the issuance of a notice of a final partnership administrative adjustment (FPAA) and a petition for a readjustment of partnership items. ⁵ See sec. 6226(a). Our decision was based on an application of the unified2002 U.S. Tax Ct. LEXIS 26">*33 partnership procedures. ⁶

Petitioner contends that "there are a number of 'affected items which require partner level determinations' (Code, Section 6230(a)(2)(A)(i)) with respect to which tax and, necessarily, interest must have been assessed as a result of this Court's decision in this matter." Petitioner points to AlliedSignal's basis in ASA Investerings Partnership and the determination of an appropriate amount of interest expense under section 1.861-8, Income Tax Regs.2002 U.S. Tax Ct. LEXIS 26">*34 , as affected items that require partner-level determination under section 6230(a)(2)(A)(i). Petitioner claims that "The assessment(s) with respect to these 'affected items,' pursuant to the provisions of Code, Section 6230(a)(2)(A)(i) of the Code, has occurred under the provisions of Subchapter B of the Code, including Section 6215." We disagree. ⁷

It is clear that a section 6215 assessment did not and could not occur in this case. Section 6215 requires a petition filed by the taxpayer with the Tax Court and an amount redetermined as the deficiency by a decision of the Tax Court which has become final. ⁸ Our2002 U.S. Tax Ct. LEXIS 26">*35 jurisdiction to redetermine a deficiency 118 T.C. 423">*427 arises only in the case of a valid notice of deficiency and the filing of a timely petition for review under section 6213(a). Savage v. Commissioner, 112 T.C. 46">112 T.C. 46, 112 T.C. 46">48 (1999); Monge v. Commissioner, 93 T.C. 22">93 T.C. 22, 93 T.C. 22">27 (1989). ⁹

2002 U.S. Tax Ct. LEXIS 26">*36 In the instant case, no notice of deficiency was issued. In the absence of a notice of deficiency, we did not and, indeed, could not have redetermined or sustained a deficiency determination made by respondent. See Saso v. Commissioner, 93 T.C. 730">93 T.C. 730, 93 T.C. 730">735 (1989) (" If we are to redetermine a deficiency, our jurisdiction is dependent upon the issuance of a notice of deficiency."). It follows that a section 6215 assessment could not have been made in this case since that Code section contemplates a redetermination of a deficiency by the Tax Court.

Petitioner, in its capacity as the tax matters partner of ASA, did file a petition with the Tax Court. However, that petition was filed pursuant to section 6226(a), not section 6213(a). A petition filed pursuant to section 6226(a) is termed "a petition for a readjustment of the partnership items". A petition filed pursuant to section 6213(a) is termed "a petition with the Tax Court for a redetermination of the deficiency". Section 6215(a) refers specifically to "the entire amount redetermined as the deficiency by the decision of the Tax Court". We interpret section 6215(a) to refer exclusively to a petition filed under section2002 U.S. Tax Ct. LEXIS 26">*37 6213(a) and a decision that was entered pursuant to the deficiency procedures contained in sections 6211-6216.

Our deficiency procedures do not extend to the adjustment of partnership items or to deficiencies attributable to computational adjustments. ¹⁰ We cannot redetermine deficiencies 118 T.C. 423">*428 under section 6226. ¹¹ See, e.g., Maxwell v. Commissioner, 87 T.C. 783">87 T.C. 783, 87 T.C. 783">787 (1986). Our prior decision in this case, ASA Investerings Pship. v. Commissioner, T.C. Memo. 1998-305, was not a decision which we made under the deficiency procedures. And, deficiencies which are attributable to computational adjustments are assessed under the general assessment authority of section 6201(a), not section 6215. Brookes v. Commissioner, 108 T.C. 1">108 T.C. 1, 108 T.C. 1">9-10 (1997). ¹²

2002 U.S. Tax Ct. LEXIS 26">*38 We hold that we do not have jurisdiction under section 7481(c) to review petitioner's motion to redetermine interest.

An appropriate order will be entered.