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Respondent also determined that petitioner is liable for
increased interest on underpayments attributable to tax-motivated
transactions as defined in section 6621(c),1 for the entire
underpayment of tax for 1980.
The sole issue for our decision is whether the statutory
periods of limitations for assessing and collecting the
deficiencies in, and additions to, petitioner's Federal income
taxes for 1980 and 1981 have expired.2 We hold they have not.
Background
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. Petitioner is an attorney
who resided in Rochester, Minnesota, at the time he filed his
petition in this case.
Petitioner filed his Federal income tax returns for the
taxable years 1980 and 1981 on June 15, 1981, and October 15,
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure. Sec. 6621(c), formerly sec. 6621(d), was
redesignated pursuant to Tax Reform Act of 1986, Pub. L. 99-514,
sec. 1511(c), 100 Stat. 2744.
2Petitioner asserts on brief that interest on the deficiency
should be abated pursuant to sec. 6404(e). Consideration of
petitioner's request for abatement of interest is premature,
however, as there has been neither an assessment of interest nor
a final determination by respondent not to abate the interest.
See sec. 6404(e), (g), as currently in effect; see also Bourekis
v. Commissioner, 110 T.C. 20, 26 (1998).
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