Paul L. and Doris J. Triemstra, et al. - Page 3

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          be calculated at 120 percent of the statutory rate under section            
               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              

               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          and repealed by sec. 7721(b) of the Omnibus Budget Reconciliation           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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