Pallottini v. Commissioner
United States Tax Court
Held, the rate of the addition to tax provided by sec. 6661, I.R.C. 1986, is 25 percent on additions assessed after Oct. 21, 1986. Tax Reform Act of 1986, sec. 1504, and Omnibus Budget Reconciliation Act of 1986, sec. 8002, construed.
1Opinion of the Court
OPINION
CHABOT, Judge:*
Respondent determined deficiencies in Federal individual income tax and additions to tax under sections 6653(b)1 (fraud) and 6661 (substantial understatement of liability), as follows:
Additions to tax2
Year Deficiency Sec. 6653(b) Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661 1981 $107,666.81 $53,833.40
1982 32,978.95 - - - $16,489.48 50 percent of $3,297.90 the interest due on $32,978.95
The addition to tax under section 6661 for 1982 was determined by respondent as 10 percent of the $32,978.95 underpayment for that year.
At trial, the parties announced a settlement of all…
2Cases cited10 opinions
- Ernst & Ernst v. HochfelderSupreme Court of the United States · 1976
- Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
- Rubin v. United StatesSupreme Court of the United States · 1981
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- Aaron v. Securities & Exchange CommissionSupreme Court of the United States · 1980
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