- 4 -
would be calculated at 120 percent of the statutory rate under
section 6621(c).
In her answer, respondent asserted negligence additions to
tax for 1979 and 1981, increased additions to tax under sections
6653(a)(2) and 6659 for 1982, and a decreased addition to tax
under section 6659 for 1981, as follows:
Year Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $13.10 -- -- --
1981 -- $768.85 1 $3,714
1982 -- -- 1 2,401
1 50 percent of the interest due on the amount of the
underpayment attributable to negligence. Respondent asserted
that the amounts of the underpayments attributable to negligence
for 1981 and 1982, respectively, were $15,377 and $9,901.
For taxable year 1982, respondent also asserted that the
increased rate of interest under section 6621(c) applied to the
entire deficiency for that year. We consider the amounts in
dispute to be adjusted accordingly.
The parties filed a Stipulation of Settled Issues concerning
the adjustments relating to petitioner Allan J. Becker's
participation in the Plastics Recycling Program. The stipulation
provides:
1. Petitioners are not entitled to any deductions,
losses, investment credits, business energy investment
credits or any other tax benefits claimed on their
1979, 1981 and 1982 returns as a result of their
participation in the Plastics Recycling Program.
2. The underpayments in income tax attributable to
petitioners' participation in the Plastics Recycling
Program are substantial underpayments attributable to
tax motivated transactions, subject to the increased
rate of interest established under I.R.C. �6621(c),
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