- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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