- 16 -
transaction. Skeen v. Commissioner, 864 F.2d 93 (9th Cir. 1989);
sec. 6621(c)(3)(A)(v). When section 6621(c) applies, the annual
rate of interest payable on the tax-motivated substantial
underpayment is increased to 120 percent of the underpayment rate
under section 6621(b).
We find that petitioners’ underpayments were not
attributable to tax-motivated transactions. We hold the same.
* * * * * * *
We have considered all arguments made by the parties and, to
the extent not discussed above, find them to be without merit.
To reflect the foregoing,
Decisions will be entered
for respondent for the
deficiencies, the additions to
tax under sec. 6661, and, with
respect to N. LaRae Sparrow,
the additions to tax under
sec. 6651(a)(1), and for
petitioners for the increased
interest under sec. 6621(c),
and, with respect to Robert D.
Sparrow, the additions to tax
under sec. 6653(b).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011