4
under section 6659 for 1982 and 1983 in the respective amounts of
$1,094 and $223. Petitioners concede that they are liable for
additions to tax in these amounts. The Stipulation of Settled
Issues states that upon entry of decision petitioners waive the
restriction contained in section 6213(a) prohibiting assessment
and collection of the section 6659 addition to tax until the
entry of the decision of the Court is final. As of February 24,
1997, petitioners had not paid any of the taxes or interest owing
with respect to tax years 1982 and 1983 which have been assessed.
On February 24, 1997, petitioners filed a motion for leave
to file an amendment to petition. That motion was granted. In
the amendment to petition, petitioners again stated that the
deficiencies in dispute include the amounts assessed against them
as a result of the decision in Anderson Equipment Associates v.
Commissioner, supra. Further, in the amendment to petition,
petitioners allege that respondent erred by not reducing the
amounts of the taxes and interest assessed by the loss of
petitioners' investment in the Barrister Series 112 and the
amount of the investment tax recapture reported by petitioners on
their 1984 tax return as a result of their interest in Barrister
Series 112. Petitioners argue that the loss and recapture are
affected items, or in the alternative that the mitigation
provisions of section 1311 through 1314 apply. Petitioners also
allege error in the assessment of interest under section 6621(c).
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