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intentional disregard of rules or regulations for the tax year
1984. We hold that it is.
(5) Whether petitioner is liable for an addition to tax
under section 6661 for a substantial understatement of tax for
1984. We hold that it is.
(6) Whether petitioner is liable for increased interest on
substantial underpayments attributable to tax-motivated
transactions under section 6621 for 1984. We hold that it is.
Some of the facts have been stipulated and are so found.
The stipulations of facts are incorporated herein by this
reference. At the time the petition was filed, petitioner was a
Delaware corporation with its principal office in Atlanta,
Georgia.
FINDINGS OF FACT
I. General
A. United Parcel Service
Petitioner is the largest motor carrier in the United States
with a principal business consisting of the pickup and delivery
of small packages and parcels. During 1983 and 1984, petitioner
conducted its business through wholly owned subsidiaries in the
United States, Canada, and West Germany. Petitioner, United
Parcel Service of America, Inc. (UPS), had several wholly owned
subsidiaries, including United Parcel Service, Inc.--New York
(UPS-New York), United Parcel Service, Inc.--Ohio (UPS-Ohio), and
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