- 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 Sec. 6621(c) was repealed by sec. 7721(b) of the Omnibus Budget Reconciliation Act of 1989 (OBRA 89), Pub.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
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