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OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: In these consolidated
cases, respondent determined deficiencies in petitioners' Federal
income taxes, additions to tax,3 penalties, and increased
interest, as follows:
Investment Research Associates, Ltd., and Subsidiaries
Docket No. 43966-85:
Addition to Tax
Year Deficiency Sec. 6659(a)
1979 $18,791 $5,637
Docket No. 45273-86:
Additions to Tax
Year Deficiency Sec. 6653 Sec. 6659(a) Sec. 6661
1982 $174,225 $8,711 $49,154 $1,038
3
With respect to the additions to tax under sec. 6653, as to
all of the cases before the Court, for the years 1979 and 1980,
the addition to tax is under sec. 6653(a). For the years 1981
through 1985, the addition to tax is under sec. 6653(a)(1). For
the years 1981 through 1985, respondent also determined the
addition to tax under sec. 6653(a)(2), which is 50 percent of the
interest due on the underpayment of tax attributable to
negligence or intentional disregard of rules or regulations. For
the years 1986 and 1987, the addition to tax is under sec.
6653(a)(1)(A), and the determined 50-percent interest due on the
underpayment is under sec. 6653(a)(1)(B). For 1988, the addition
to tax is under sec. 6653(a)(1), and there is no corresponding
addition to tax for 50 percent of the interest due on the
underpayment. See Technical and Miscellaneous Revenue Act of
1988, Pub. L. 100-647, sec. 1015(b)(2)(A), 102 Stat. 3342, 3568,
applicable to returns the due date for which, without regard to
extensions, is after Dec. 31, 1988.
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