2
Additions to Tax Additional Interest
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c)
1975 $ 4,847 $242 -- -- --
1976 4,946 247 -- -- --
1977 6,576 329 -- -- --
1978 7,231 362 -- -- --
1979 6,789 339 -- -- --
1980 11,655 583 -- -- --
1981 13,081 -- $654 1 $3,924
1982 9,751 -- 488 1 2,925
1 50 percent of the interest due to the underpayment of tax attributable to negligence or
intentional disregard of rules and regulations.
2 120 percent of the interest due with respect to any substantial underpayment attributable to
tax motivated transactions.
After concessions reflected in the Stipulation of Settled
Issues, filed March 24, 1995,2 the issue for decision is whether
petitioners are entitled to an investment tax credit for the
taxable year 1978, and, if so, in what amount, and whether they
are entitled to any related carrybacks. This case was submitted
fully stipulated pursuant to Rule 122. The stipulation of facts
and the attached exhibits are incorporated herein by this
reference. Petitioners resided in Fair Oaks, California, at the
2 In their Stipulation of Settled Issues, the parties
stipulated that, exclusive of the investment tax credit issue,
there are deficiencies in petitioners' Federal income taxes as
follows:
Taxable Year Deficiency
1975 $4,847
1976 4,946
1977 6,727
1978 1,495
1979 1,549
1980 9,043
1981 8,750
1982 3,468
The parties further stipulated that there are no additions to tax under
secs. 6653(a), 6653(a)(1), 6653(a)(2), and 6659 for any of the years in issue,
and that no part of the deficiencies is a substantial underpayment for the
purposes of computing interest payable with respect to such amounts pursuant
to sec. 6621(c) (formerly sec. 6621(d)).
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