Anthony J. and Claire L. Pace - Page 28

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          motivated transaction is an integral part of, or inseparable                
          from, the ground for disallowance of an item, section 6621(c)               
          increased interest applies.  See McCrary v. Commissioner, 92 T.C.           
          at 859.  Petitioners stipulated substantially the same facts                
          regarding the underlying transaction in these cases as we found             
          in Provizer v. Commissioner, T.C. Memo. 1992-177, where we held             
          that the taxpayers were liable for the section 6659 addition to             
          tax because the underpayment of taxes was directly related to the           
          overvaluation of the Sentinel EPE recyclers.  In the present                
          cases we have likewise found that overvaluation of the recyclers            
          was an integral part of the ground for disallowance of the items            
          related to Hyannis.  Accordingly, respondent's determination as             
          to the applicable interest rate for deficiencies attributable to            
          tax-motivated transactions is sustained, and the increased rate             
          of interest applies for the taxable year in issue.                          
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                        under Rule 155.                               














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