- 3 - $37,959.55 and also determined that interest on deficiencies accruing after December 31, 1984, would be calculated at 120 percent of the statutory rate under section 6621(c).2 In a notice of deficiency, respondent determined the following deficiencies in and additions to Sorey's Federal income taxes: Increased Interest Additions to Tax Year Deficiency Sec. 6621(c) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 1978 $10,022 1 --- --- $3,006.60 1979 382 --- --- --- 114.60 1981 11,737 1 $586.85 2 3,521.10 1120 percent of the interest payable under sec. 6601 with respect to any substantial underpayment attributable to tax-motivated transactions. 250 percent of the interest payable with respect to the portion of the underpayment attributable to negligence. The deficiencies in the Sorey case, docket No. 7908-89, for taxable years 1978 and 1979 result from disallowance of investment tax credit carrybacks and business energy credit carrybacks from taxable year 1981. In addition to the above deficiencies and additions to tax, in amended answers, respondent asserted the following: (1) In the Wilson case, docket No. 2 The notice of deficiency in the Wilson case, docket No. 21243-85, refers 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 L. 99-514, 100 Stat. 2085, 2744, and repealed by sec. 7721(b) of the Omnibus Budget Reconciliation Act of 1989 (OBRA 89), Pub.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 shall refer to this section as sec. 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
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