- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011