Peter and Ursula Reimann, et al. - Page 3

                                        - 3 -                                         
          (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  Sec. 6621(c) was repealed by sec.                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.                                 




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011