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          deficiency also state that interest will be computed on the                 
          addition to tax under section 6651(a)(1) for the taxable year               
          1986 pursuant to section 6601(e)(2).3                                       
               On August 17, 1995, respondent issued notices of deficiency            
          to Pen Holdings, Inc., and its subsidiaries (Pen Holdings) in               
          which respondent determined the following deficiencies in, and              
          additions to, Pen Holdings' Federal income taxes:                           

                         imposed by subtitle A, the taxable                           
                         year, or                                                     
                              (ii) in the case of any other                           
                         tax, the period to which the                                 
                         underpayment relates.                                        
               3Sec. 6601(e)(2)(B) provides in pertinent part:                        
               SEC. 6601(e).  Applicable Rules.--Except as otherwise                  
               provided in this title--                                               
          *     *     *     *     *     *     *                                       
                    (2) Interest on penalties, additional amounts, or                 
               additions to the tax.--                                                
          *     *     *     *     *     *     *                                       
                         (B) Interest on certain additions to                         
                    tax.--Interest shall be imposed under this                        
                    section with respect to any addition to tax                       
                    imposed by section 6651(a)(1) * * * for the                       
                    period which--                                                    
                              (i) begins on the date on                               
                         which the return of the tax with                             
                         respect to which such addition to                            
                         tax is imposed is required to be                             
                         filed (including any extensions),                            
                              (ii) ends on the date of                                
                         payment of such addition to tax.                             

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