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Additions To Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6661
1982 $1,457,191 -- $364,298
1983 990,664 -- 247,666
1984 1,510,584 -- 377,646
1985 2,317,050 $175,058 579,263
1986 5,102,222 -- 1,275,556
1987 4,229,739 -- 158,778
1988 3,181,108 -- --
Respondent also determined that Pen Holdings' underpayments for
the taxable years 1982 through 1988 constitute large corporate
underpayments within the meaning of section 6621(c)(3) and that
Pen Holdings is therefore liable for interest computed at the
increased rate prescribed in section 6621(c)(1). The notices of
deficiency also state that interest will be computed on the
addition to tax under section 6651(a)(1) for the taxable year
1985 pursuant to section 6601(e)(2).
On August 17, 1995, respondent issued additional notices of
deficiency to Pen Holdings in which respondent determined the
following deficiencies in, and additions to, Pen Holdings'
Federal withholding taxes under chapter 3 of subtitle A:
Addition To Tax
Year Deficiency Sec. 6651(a)(1)
1982 $676,894 $169,223
1983 972,657 243,164
1984 729,143 182,286
1985 1,079,888 269,972
Respondent also determined that Pen Holdings' underpayments for
the taxable years 1982 through 1985 constitute large corporate
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