- 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),Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011