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filed an amendment to answer and asserted additions to tax for
1981 in the amount of $2,611 under section 6653(a)(1) for
negligence and under section 6653(a)(2) in an amount equal to 50
percent of the interest due on the underpayment attributable to
negligence. Respondent also claimed therein that petitioners had
an underpayment of tax on their 1981 return attributable to a
valuation overstatement and asserted an addition to tax under
section 6659 in an amount equal to 30 percent of the underpayment
attributable to valuation overstatement.
In a notice of deficiency dated December 14, 1989,
respondent determined a deficiency in the 1981 joint Federal
income tax of petitioners Berry in the amount of $29,978 and
additions to tax for that year in the amount of $11,881 under
section 6659 for valuation overstatement, in the amount of $2,489
under section 6653(a)(1) for negligence, and under section
6653(a)(2) in an amount equal to 50 percent of the interest due
on the underpayment attributable to negligence. On March 14,
1994, respondent filed an amendment to answer and asserted that
interest on deficiencies accruing after December 31, 1984, should
be calculated at 120 percent of the statutory rate under section
6621(c).
2(...continued)
6621(c). The annual rate of interest under sec. 6621(c) for
interest accruing after Dec. 31, 1984, equals 120 percent of the
interest payable under sec. 6601 with respect to any substantial
underpayment attributable to tax-motivated transactions.
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