- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011