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Docket No. 22884-93:
Penalty
Year Deficiency Sec. 6662
1989 $179,924 $35,985
Estate of Robert W. Lisle, Deceased, Thomas W. Lisle and Amy L.
Albrecht, Independent Co-executors, and Estate of Donna M. Lisle,
Deceased, Thomas W. Lisle and Amy L. Albrecht, Independent Co-
executors
Additions to Tax Penalty
Docket No. Year Deficiency Sec. 6653 Sec. 6661 Sec. 6662(a)
20219-91 1984 $827,955 $41,397.75 $206,988.75 --
21555-91 1987 195,498 9,774.90 48,874.50 --
16164-92 1988 109,048 5,452.00 27,262.00 --
7557-93 1989 109,049 -- -- $21,810
In the following cases, respondent determined in the notices
of deficiency or asserted in amended answers that the
underpayments in tax were subject to increased interest under
section 6621(c), formerly section 6621(d):4
Investment Research Associates, Ltd., and Subsidiaries:
Docket No. Year
43966-85 1979
45273-86 1982
4
Sec. 6621(d)(1) was added by the Deficit Reduction Act of
1984, Pub. L. 98-369, sec. 144(a), 98 Stat. 682, and provides for
interest of 120 percent of the adjusted interest rate due on any
substantial underpayment of tax attributable to tax-motivated
transactions. The increased interest is effective for interest
accruing after Dec. 31, 1984. Sec. 6621(d) was redesignated as
sec. 6621(c) by sec. 1511(c)(1)(A) of the Tax Reform Act of 1986,
Pub. L. 99-514, 100 Stat. 2085, 2744, and repealed by sec.
7721(b) of the Omnibus Budget Reconciliation Act of 1989 (OBRA
89), Pub. L. 101-239, 103 Stat. 2106, 2399, effective for tax
returns due after Dec. 31, 1989, OBRA 89 sec. 7721(d), 103 Stat.
2400.
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