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(EPE) recyclers by partnerships in which petitioners held limited
partnership interests. The facts of the underlying transactions
in these cases are substantially identical to those in the
Provizer case.
In notices of deficiency, respondent determined the
following deficiencies in and additions to petitioners' Federal
income taxes for taxable year 1981:
Additions to Tax
Docket No. Petitioner Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
9915-86 Peter and Ursula Reimann $43,025.11 --- --- $8,873.10
35003-86 Edward Brodie and Estate
of Alana Brodie 22,711.72 --- --- 7,944.52
3398-92 Marvin and Suzanne Yarnell 165,899.00 $7,716 1 49,770.00
13892-92 Philip and Roberta Yarnell 133,225.00 6,051 1 36,303.00
1 50 percent of the interest payable with respect to the portion of the underpayment attributable to
negligence.
Respondent also determined in each case that interest on
deficiencies accruing after December 31, 1984, would be
calculated at 120 percent of the statutory rate under section
6621(c).3 In docket Nos. 9915-86 and 35003-86, in amendments to
the answers, respondent asserted additions to tax for 1981 under
section 6653(a)(1) in the respective amounts of $2,151 and
3
The notices of deficiency in docket Nos. 9915-86 and 35003-
86 refer to sec. 6621(d). Sec. 6621(c) was repealed by sec.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 cases. 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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