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On February 2, 1990, the parties filed a stipulation of
settled issues that resolved some of the issues in dispute. On
March 28, 1990, respondent filed a First Request for Admissions
(First Request). Respondent mailed her First Request to
petitioner at four different addresses, including the address
provided by petitioner in the stipulation of settled issues. On
April 13, 1990, respondent notified the Court that her First
Request had subsequently been mailed to petitioner at still
another address in Boca Raton, Florida. Petitioner did not
answer or object to respondent's First Request.
On August 3, 1993, respondent filed a Second Request for
Admissions (Second Request) and mailed it to petitioner at the
Boca Raton address in Florida. Petitioner did not answer or
object to respondent's Second Request. By Order dated October 5,
1993, the Court requested petitioner and respondent to file
Status Reports with the Court before November 5, 1993.
2(...continued)
section 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and repealed by sec. 7721(b) of the Omnibus Budget Reconciliation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 simplicity, we will 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.
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