- 16 - that there is a valuation overstatement in this case to which section 6659 applies. Thus, the increased rate of interest under section 6621(c) automatically applies to underpayments of tax attributable to petitioners' investment in Century. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011