- 66 - accrued on this item at the section 6621(c) rate. On opening brief, petitioners contend that the section 6621(c) rate should apply to only $1,137 of this item. On answering brief, respondent concedes that the section 6621(c) rate should apply to only $1,137 of the $1,144 additional assessment. These agreements are to be given effect in the computation under Rule 155. As to any other questions regarding the section 6621(c) rate, we note that the parties’ settlement in petitioners’ deficiency case includes the determination that: the entire underpayment in income tax for the taxable years 1978, 1979, 1981 and 1982 is a substantial underpayment attributable to tax-motivated transactions for purposes of computing the interest payable with respect to such amount pursuant to I.R.C. � 6621(c), formerly I.R.C. � 6621(d); This agreement by the parties in petitioners’ deficiency case was part of the decision we entered disposing of that case. Apart from the above-noted stipulation and the above-noted concession, we hold for respondent on this issue. III. The $40,000 Offer in Compromise In May 1996 (supra note 8) petitioners sent to respondent a check in the amount of $40,000 as part of an offer in compromise to settle their interest liability for 1978, 1979, 1981, and 1982. At Fish’s request, on September 4, 1996, petitioners withdrew their offer in compromise. At some point, probably in December 1996, possibly in January 1997, respondent refunded to petitioners the $40,000, without interest.Page: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 Next
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