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Additions to Tax
Year DeficiencySec. 6659 Sec. 6653(a)Sec. 6653(a)(1)Sec. 6653(a)(2)
1980 $89,410 $26,768 $4,470 --- ---
1981 36,601 10,980 --- $1,830 50% of the
interest due on
$36,601
1982 4,602 1,381 230 50% of the
interest due on
$4,602
Respondent also determined that, pursuant to section 6621,
interest on substantial underpayments attributable to tax-
motivated transactions for the taxable years 1980, 1981, and 1982
would be 120 percent of the adjusted rate.
The petition was filed on December 15, 1986.
On December 31, 1986, decedent made a single voluntary
payment of $185,327. As of the same date, respondent credited
$89,410 to decedent's account for the taxable year 1980 as a
"Subsequent Payment". This amount equaled the 1980 income tax
deficiency determined by respondent. Under respondent's
procedures, a "Subsequent Payment" designation is used when a
taxpayer does not make a designation with respect to whether a
remittance constitutes a payment of tax or a deposit in the
nature of a cash bond.
Respondent credited the remaining $95,917 to decedent's
account for the taxable year 1980 as a "Designated Interest
Payment".
On July 13, 1992, respondent transferred the following
amounts out of decedent's account for the taxable year 1980 and
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