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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:
2(...continued)
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),
and
(ii) ends on the date of
payment of such addition to tax.
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