- 3 -
be calculated at 120 percent of the statutory rate under section
6621(c).3
Petitioners have conceded that they are liable for the
deficiencies in tax, the section 6659 additions to tax, and the
section 6621(c) additional interest as determined in respondent's
notices of deficiency.
The sole issue for decision is whether petitioners are
liable for additions to tax for 1981 for negligence or
intentional disregard of rules or regulations under section
6653(a)(1) and (2).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated by
this reference.
Petitioners Jeffrey and Fran Kravitz resided in Birmingham,
Michigan, when their petition was filed. Petitioners Paul and
Doris Triemstra resided in Troy, Michigan, when their petition
3
The notices of deficiency refer to sec. 6621(d). This
section was redesignated as sec. 6621(c) by sec. 1511(c)(1)(A) of
the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2744,
and repealed by sec. 7721(b) of the Omnibus Budget Reconciliation
Act of 1989 (OBRA 1989), Pub. L. 101-239, 103 Stat. 2106, 2399,
effective for tax returns due after Dec. 31, 1989, OBRA 89, sec.
7721(d), 103 Stat. 2400. The repeal does not affect the instant
cases. For simplicity, we will refer to this section as sec.
6621(c). The annual rate of interest under sec. 6621(c) for
interest accruing after Dec. 31, 1994, 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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