Tom I. Lincir and Diane C. Lincir - Page 11




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          however, that section 6621(d) does not affect the computation of              
          the addition to tax.  Petitioners contend that the proper                     
          application of section 6621(d) will have the effect of reducing               
          the amount of the addition to tax under section 6653(a)(2)                    
          because there should not be any interest due with respect to the              
          portion of petitioners' income tax liabilities for the years in               
          issue that is offset by petitioners' income tax overpayments for              
          1984 and 1985.                                                                
               Section 6653(a)(2) provides that, if a portion of an                     
          underpayment is attributable to negligence, the taxpayer shall be             
          liable for an addition to tax "in an amount equal to 50 percent               
          of the interest payable under section 6601".  The specific amount             
          of a taxpayer's liability for the addition to tax under section               
          6653(a)(2) is dependent upon a computation of statutory interest              
          payable under section 6601.                                                   
               To date, respondent has not assessed or otherwise computed               
          the statutory interest payable under section 6601 in this case.               
          In short, respondent cannot make such a computation until the                 
          Court has entered its decision.  Because respondent has not                   
          computed the amount of statutory interest payable under section               
          6601, any question pertaining to the correct computation of the               
          addition to tax under section 6653(a)(2) is premature and is not              
          ripe for consideration.  We note that until respondent computes               
          and enters an assessment for the addition to tax under section                
          6653(a)(2), it is unclear whether the present computational                   




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