Penalty
Additions to Tax
Docket No. Petitioner Year Deficiency Sec. 6621(c) Sec. 6653(a)(1) Sec.
6653(a)(2) Sec. 6659
12091-89 Bruce and Lois Zenkel 1979 $26,330.001 2 --
-- $ 7,899.004
1980 483.001 -- --
-- --
1982 72,349.00 2 $3,617.00
3 21,705.004
19760-89 Robert G. Blount 1981 52,662.49 2 2,633.12
3 15,798.75
24512-89 Morton and Carol David 1982 51,356.00 2 2,569.00
3 15,407.004
10147-91 Ira and Helen Selvin 1981 44,626.00 2 2,231.00
3 13,388.00
1The deficiencies in docket No. 12091-89 for taxable years 1979 and 1980 result from disallowance of investment tax
credit carrybacks and business energy credit carrybacks from taxable year 1982.
2Sec. 6621(c) was repealed by sec. 7721(b) of the Omnibus Budget Reconciliation Act of 1989 (OBRA 89), Pub.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. 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.
350 percent of the interest payable with respect to the portion of the underpayment attributable to negligence.
4In the alternative to the addition to tax under sec. 6659, respondent also determined that petitioners'
underpayments were subject to the addition to tax under sec. 6661.
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Last modified: May 25, 2011