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attributable to a tax-motivated transaction for purposes of
computing the interest payable with respect to such amount,
pursuant to section 6621(c). With respect to the addition to tax
under section 6653(a)(2), petitioners concede that the entire
underpayment of income tax is due to negligence, but dispute the
applicability of section 6653(a)(2).
The sole issue for decision is whether the effective date of
section 6653(a)(2) precludes application of that section to a
portion of the deficiency equal to three installments of
estimated tax paid during 1981.
The parties submitted this case fully stipulated. The
stipulated facts and attached exhibits are incorporated herein by
this reference. Petitioners resided in New York, New York, at
the time their petition was filed.
On April 15, June 17, and September 18, 1981, petitioners
made three payments of estimated tax for taxable year 1981, each
in the amount of $13,000.2 Petitioners made a fourth and final
payment of estimated tax for taxable year 1981 on January 18,
1982, in the amount of $30,000. On April 15, 1982, petitioners
filed a Form 4868, Application for Automatic Extension of Time to
File U.S. Individual Income Tax Return, and included a payment of
$10,000. After requesting another extension of time to file,
2 Also on Apr. 15, 1981, an overpayment in the amount of
$3,388 from the prior tax period was credited towards
petitioners' 1981 estimated tax.
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