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section 66591 for valuation overstatement, in the amount of
$495.05 under section 6653(a)(1) for negligence, and under
section 6653(a)(1)(B)2 in an amount equal to 50 percent of the
interest due on the amount of the underpayment attributable to
negligence. Respondent also determined that interest on the
deficiency accruing after December 31, 1984, would be calculated
at 120 percent of the statutory rate under section 6621(c). Both
the increased rate of interest and the additional interest for
negligence were calculated on the amount of $1,899.
In a second notice of deficiency dated September 6, 1989,
respondent determined a deficiency in petitioners' 1979 joint
Federal income tax in the amount of $262. The deficiency for
taxable year 1979 was due entirely to the disallowance of an
investment credit carryback from 1982.
In a notice of deficiency dated October 5, 1989, respondent
determined a deficiency in petitioner Allan J. Becker's 1981
Federal income tax in the amount of $15,377, and an addition to
tax for that year in the amount of $4,613 under section 6659 for
valuation overstatement. Respondent also determined that
interest on the deficiency accruing after December 31, 1984,
1 In the alternative to the sec. 6659 addition to tax,
respondent determined an addition to tax under sec. 6661 for
substantial understatement of liability.
2 For taxable year 1982, the addition to tax for negligence in
an amount equal to 50 percent of the interest due on the amount
of the underpayment attributable to negligence was provided for
under sec. 6653(a)(2), not sec. 6653(a)(1)(B).
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