Abraham and Dina Weiss - Page 24




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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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