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          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                 
          additions to tax under section 6651(a)(1) for the taxable years             
          1982 through 1985, pursuant to section 6601(e)(2).                          
               All references to petitioners are to Pen Coal and Pen                  
          Holdings (and its subsidiaries).                                            
               On November 14, 1995, petitioners separately filed petitions           
          for redetermination with this Court contesting the notices of               
          deficiency described above.  Each of the petitions contains                 
          allegations that respondent erred in her determinations regarding           
          the imposition of interest under sections 6601(e)(2) and                    
          6621(c)(1).  Specifically, petitioners allege that they are not             
          liable for interest computed at the increased rate prescribed in            
          section 6621(c) because petitioners do not have a "large                    
          corporate underpayment" for any of the taxable years in issue.              
          In the alternative, petitioners allege that respondent failed to            
          allow them an opportunity for administrative review prior to the            
          issuance of the notices of deficiency and that, as a consequence,           
          the applicable date for computing increased interest under                  
          section 6621(c) is the date that the notices of deficiency were             

               4We note that pursuant to sec. 6621(c)(2)(A)(ii), the                  
          "applicable date" is the 30th day after the date on which the               

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Last modified: May 25, 2011