- 2 - Year Deficiency 1978 $93,098 1979 84,284 1980 28,675 Respondent also determined that petitioners are liable for increased interest pursuant to section 6621(c) (formerly section 6621(d))1 for the taxable years 1978, 1979, and 1980. After concessions by the parties, the sole issue for decision is whether Arlene Jacoby (petitioner) is entitled to relief as an innocent spouse for the taxable years 1978, 1979, and 1980. We hold that she is so entitled. Petitioner Gerald Jacoby (Gerald) has reached a settlement with respondent regarding his liabilities for all taxable years. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. 1 Sec. 6621(d) was redesignated as sec. 6621(c) by sec. 1511(c)(1)(A) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2744, and repealed by sec. 7721(b) of the Omnibus Budget Reconciliation Act of 1989 (OBRA 89), Pub. L. 101-239, 103 Stat. 2106, 2399, effective for tax returns due after Dec. 31, 1989, OBRA 89 sec. 7721(d), 103 Stat. 2400. The repeal does not affect the instant case. For convenience, we refer to this section as sec. 6621(c). The annual rate of interest under sec. 6621(c) for interest accruing after Dec. 31, 1984, equals 120 percent of the interest payable under sec. 6601 with respect to any substantial underpayment attributable to tax-motivated transactions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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