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in which the underpayment is "attributable to 1 or more tax
motivated transactions". Sec. 6621(c)(2). Temporary regulations
adopted pursuant to section 6621(c)(3))(B), which are applicable
to interest accruing after December 31, 1984, state that "Any
deduction disallowed for any period under section 183" is subject
to the provision for additional interest set forth in section
6621(c). Sec. 301.6621-2T, A-4(1), Temporary Proced. & Admin.
Regs., 49 Fed. Reg. 50392 (Dec. 28, 1984). Here, respondent has
explicitly determined that the deductions at issue are disallowed
under section 183. Petitioners have not shown that
determination to be erroneous. Respondent is therefore entitled
to additional interest after December 31, 1984, on the portion of
the deficiencies for 1976, 1977, and 1978 attributable to the
disallowed deductions.
To give effect to concessions,
Decision will be entered
under Rule 155.
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