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provided an increased rate of interest for substantial
underpayments attributable to tax-motivated transactions.
Substantial underpayments are defined as underpayments in excess of
$1,000. By regulation, among the types of transactions that are
considered to be tax-motivated transactions within the meaning of
section 6621(c) are those with respect to which the related tax
deductions are disallowed under section 183 for lack of profit
objective. Rybak v. Commissioner, 91 T.C. 524, 568 (1988); sec.
301.6621-2T, A-4(1), Temporary Proced. & Admin. Regs., 49 Fed. Reg.
50392 (Dec. 28, 1984). In light of our findings as to the lack of
profit objective, petitioners are liable for increased interest
under section 6621(c).
For the reasons stated, respondent's imposition of the
additions to tax is not sustained in these cases, but respondent's
imposition of increased interest under section 6621(c) is
sustained.
Decisions will be entered
under Rule 155.
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