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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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