Anthony J. and Claire L. Pace - Page 3

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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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