115 T.C. No. 22 UNITED STATES TAX COURT TOM I. LINCIR AND DIANE C. LINCIR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent1* Docket No. 22934-89. Filed September 27, 2000. Ps are liable for deficiencies in and additions to their Federal income tax liabilities for the taxable years 1978 through 1982, including interest at the increased rate prescribed under sec. 6621(c), I.R.C., and the "interest sensitive" addition to tax under sec. 6653(a)(2), I.R.C., for 1981 and 1982. The parties agree that Ps are entitled to refunds for overpayments for the taxable years 1984 and 1985 that would partially offset the deficiencies for the earlier years. Ps contend that the Court's decision for the taxable years 1978 through 1982 should state that "The penalties due under section 6621(c) and section 6653(a)(2) are to be determined after the application of the interest-netting rules of section 6621(d)." Held: The Court lacks jurisdiction in this deficiency proceeding to determine the impact, if any, of the so-called interest-netting rule under sec. 6621(d), I.R.C., on the computation of the sec. *This supplements Lincir v. Commissioner, T.C. Memo. 1999-98.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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