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addition should be computed based only on the interest accruing
on the underpayment that existed between the filing of the
original 1983 return and the filing of the amended return in
1986.
Section 6653(a)(1) provides that if any part of any
"underpayment" of tax is due to negligence, there shall be added
to the tax an amount equal to 5 percent of the "underpayment".
Under section 6653(a)(2), in addition to the above amount, there
shall be added to the tax an amount equal to 50 percent of the
interest due with respect to the portion of the "underpayment"
that is due to negligence.
For purposes of section 6653, the term "underpayment" is
defined in section 6653(c)(1) for income tax as:
a deficiency as defined in * * * [section 6211] (except
that, for this purpose, the tax shown on a return
referred to in section 6211(a)(1)(A) shall be taken
into account only if such return was filed on or before
the last day prescribed for the filing of such return,
determined with regard to any extension of time for
such filing) * * *
Therefore, for purposes of determining the existence and amount
of any "underpayment" of tax for purposes of the negligence
additions of section 6653(a)(1) and (2), the additional tax shown
on petitioners' amended return for 1983 cannot be considered.10
Crocker v. Commissioner, 92 T.C. 899, 916 (1989); Emmons v.
10The last date prescribed for filing petitioners' Federal
income tax return for 1983 was Apr. 15, 1984. Secs. 6672, 6012.
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