Tom I. Lincir and Diane C. Lincir - Page 2

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               6621(c), I.R.C., interest.  Held, further, Because R                     
               has not computed the amount of statutory interest                        
               payable under sec. 6601, I.R.C., the question of the                     
               impact of sec. 6621(d), I.R.C., if any, on the                           
               computation of the addition to tax under sec.                            
               6653(a)(2), I.R.C., is not ripe for consideration.                       

               Michael D. Savage, for petitioners.                                      
               Gary D. Kallevang, for respondent.                                       

                                 SUPPLEMENTAL OPINION                                   

               DAWSON, Judge:  This matter is before the Court for                      
          resolution of the parties' dispute over the terms of the decision             
          to be entered in this case pursuant to Rule 155.1  Although the               
          parties generally agree as to the decision to be entered in this              
          case, petitioners contend that it should include the following                
               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).                        
          Respondent opposes the inclusion of the preceding statement in                
          the decision.  As explained in detail below, the decision will                
          not include the disputed statement.                                           
               During the taxable years 1978 through 1982, Tom I. Lincir                
          and Diane C. Lincir (petitioners) reported tax losses related to              

               1  Unless otherwise indicated, section references are to                 
          sections of the Internal Revenue Code, as amended, and Rule                   
          references are to the Tax Court Rules of Practice and Procedure.              

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