- 2 -
Increased
Additions to Tax Interest
Year Deficiencies Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 Sec. 6661 Sec.
6621(c)
1982 $38,858.88 $1,942.94 1 $10,118.45 2 3
1983 26,826.77 1,341.34 1 8,048.03 2 3
1984 40,618.76 2,030.94 1 12,185.63 2 3
150 percent of the interest due on the entire deficiency.
225 percent of the understatement of tax (determined alternatively to the
additions under sec. 6659).
3Interest computed at 120 percent of the normal rate.
Respondent concedes that petitioners are not liable for additions
to tax under sections 6653, 6659, and 6661 of the Internal
Revenue Code.1 Respondent, however, continues to assert that
petitioners are liable for increased interest under section
6621(c).
The issues we must decide in the instant case are: (1)
Whether Ronald Kimmich (petitioner) is "at risk" with respect to
debt incurred as part of a computer leasing transaction that he
entered into during 1982; and (2) whether petitioners are liable
for increased interest on tax underpayments attributable to tax-
motivated transactions under section 6621(c) for each of the tax
years in issue.
1 Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011