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deficiency that petitioner was liable for the time sensitive
addition to tax under section 6653(a)(2) and the increased rate
of interest under section 6621(c).
Following concessions by the parties, we must decide:
1. Whether petitioner is liable for an addition to tax
under section 6659 equal to 30 percent of the deficiency arising
from a disallowed investment tax credit and loss that petitioner
claimed from a partnership named Grade Partners (Grade), and
2. Whether petitioner is liable for the increased rate of
interest under section 6621(c) on the deficiency.
We hold for respondent as to both issues. Section
references are to the Internal Revenue Code in effect for the
year in issue. Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
The parties have filed with the Court a stipulation of facts
and accompanying exhibits. We find the stipulated facts
accordingly, and we set forth the relevant facts in this
background section. We also set forth in this section facts
which we find from the exhibits and from matters which petitioner
admitted under Rule 90. Petitioner resided in New York, New
York, when she petitioned the Court.
Petitioner timely filed her 1981 Federal income tax return.
She claimed thereon a $689 loss from Grade, a $9,380 investment
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