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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
statement:
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.
Background
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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