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underpayment" (an underpayment in excess of $1,000) in a taxable
year "attributable to 1 or more tax motivated transactions".
Respondent argues that petitioner's deduction was a tax-motivated
transaction because it involved a valuation overstatement within
the meaning of section 6659(c). Sec. 6621(c)(3)(A)(i). Because
we do not find any valuation overstatement within the meaning of
section 6659(c), the increased interest under section 6621(c)
does not apply.
Decision will be entered
under Rule 155.
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