Lincir v. Commissioner
United States Tax Court
Ps are liable for deficiencies in and additions to their Federal income tax liabilities for the taxable years 1978 through 1982, including interest at the increased rate prescribed under sec. 6621(c), I.R.C., and the "interest sensitive" addition to tax under sec. 6653(a)(2), I.R.C., for 1981 and 1982. The parties agree that Ps are entitled to refunds for overpayments for the taxable years 1984 and 1985 that would partially offset the deficiencies for the earlier years.
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Ps are liable for deficiencies in and additions to their Federal income tax liabilities for the taxable years 1978 through 1982, including interest at the increased rate prescribed under sec. 6621(c), I.R.C., and the "interest sensitive" addition to tax under sec. 6653(a)(2), I.R.C., for 1981 and 1982. The parties agree that Ps are entitled to refunds for overpayments for the taxable years 1984 and 1985 that would partially offset the deficiencies for the earlier years. Ps contend that the Court's decision for the taxable years 1978 through 1982 should state that "The penalties due under…
1Opinion of the Court
SUPPLEMENTAL OPINION
Dawson, Judge:
This matter is before the Court for resolution of the parties’ dispute over the terms of the decision to be entered in this case pursuant to Rule 155.1 Although the parties generally agree as to the decision to be entered in this case, petitioners contend that it should include the following statement:
The penalties due under section 6621(c) and section 6653(a)(2) are to be determined after the application of the interest-netting rules of section 6621(d).
Respondent opposes the inclusion of the preceding statement in the decision. As explained in detail below,…
2Cases cited8 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- Judge v. CommissionerUnited States Tax Court · 1987
- White v. CommissionerUnited States Tax Court · 1990
- Alphonso Bax and Alice Corrine Bax, Deceased, and Alphonso L. Bax, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
3 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Estate of Smith v. Comm'rUnited States Tax Court · 2004
- Abrahamsen v. Comm'rUnited States Tax Court · 2014
- Lincir v. Comm'rUnited States Tax Court · 2007
- Abrahamsen v. Comm'rUnited States Tax Court · 2014
- Clifford A. Abrahamsen & Sole K. Abrahamsen v. CommissionerUnited States Tax Court · 2014
6 more not listed; retrieve them via the Exa API.