3
29, 1996, respondent made a second assessment of interest,
including additional interest under section 6621(c).
On April 1, 1996, respondent made an assessment for 1982
against petitioners as a computational adjustment resulting from
the partnership adjustments and an assessment for interest,
including additional interest under section 6621(c). On or
around May 6, 1996, respondent made a second assessment of
interest including additional interest under section 6621(c).
In separate notices of deficiency issued on April 2, 1996,
respondent determined additions to tax for negligence under
section 6653(a)(1) and (2) and for the substantial understatement
of tax liability under section 6661 for 1982 and 1983. The
additions to tax are affected items in that they are based on
taxes assessed against petitioners as a result of adjustments to
partnership items of Barrister Series 112.
Petitioners filed a timely petition for redetermination of
the additions to tax for 1982 and 1983 and of income taxes for
1982 and 1983 previously assessed by respondent.
This case was called for trial in Dallas, Texas, on February
24, 1997. At that time, the parties filed a Stipulation of
Settled Issues in which they stipulated that petitioners are not
liable for additions to tax under sections 6653(a)(1),
6653(a)(2), and 6661 for the taxable years 1982 and 1983.
Pursuant to section 6214(a), respondent asserted additions to tax
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