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of $1,158 under section 6653(a)(1), and under section 6653(a)(2)
in an amount equal to 50 percent of the interest due on the
underpayment attributable to negligence. Respondent also
asserted that only $23,163 of the deficiency is subject to the
increased rate of interest under section 6621(c).
In a notice of deficiency dated September 30, 1991,
respondent determined deficiencies in the 1978, 1980, 1981, and
1982 Federal income taxes of petitioner David E. Morgan (Morgan)
in the respective amounts of $23,031, $38,491, $33,928, and
$6,618. The deficiencies for taxable years 1978 and 1980 are due
all or in part to respondent's disallowance of an investment
credit carryback from taxable year 1981. Respondent also
determined the following additions to tax.
Additions to Tax
Year Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1978 $1,152 -- -- $6,909
1980 1,925 -- -- 2,643
1981 -- $1,696 1 4,275
1982 -- 331 1 --
150 percent of the interest payable with respect to the portion of the
underpayment attributable to negligence.
In her answer to petition, respondent asserted that interest on
deficiencies accruing after December 31, 1984, would be
calculated at 120 percent of the statutory rate under section
6621(c).
The parties in these consolidated cases each filed
Stipulations of Settled Issues relating to their participation in
the Plastics Recycling Program. These stipulations are virtually
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