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31, 1984, would be calculated at 120 percent of the statutory
rate under section 6621(c). The increased interest was
calculated on the amount of $6,619. In her answer, respondent
asserted that the entire deficiency was subject to the increased
rate of interest under section 6621(c). In her trial memorandum,
respondent asserted that the section 6659 addition to tax should
be reduced to $1,550, and that only $6,619 of the deficiency was
subject to section 6621(c) (as originally determined in the
notice of deficiency). We consider the amounts in dispute in
docket No. 18885-89 to be adjusted accordingly.
In a notice of deficiency dated August 18, 1989, respondent
determined a deficiency in petitioners' 1981 Federal income tax
in the amount of $20,837, and additions to tax for that year in
the amount of $1,299 under section 6659 for valuation
overstatement, in the amount of $1,042 under section 6653(a)(1)
for negligence, and under section 6653(a)(2) in an amount equal
to 50 percent of the interest due on the amount of the
underpayment attributable to negligence. Respondent also
determined that interest on deficiencies accruing after December
31, 1984, would be calculated at 120 percent of the statutory
rate under section 6621(c). The increased interest was
calculated on the amount of $4,329. In an amendment to answer,
respondent asserted an increased addition to tax under section
6659 in the amount of $4,952, and also asserted that the entire
deficiency of $20,837 was subject to the increased rate of
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