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FORSETH v. COMMISSIONER

Docket Nos. 27126-82, 1685-83, 7702-83, 7703-83, 32763-83, 2544-84, 3346-84.

50 T.C.M. 111 (1985)

T.C. Memo. 1985-279

Arnold T. Forseth, et al. v. Commissioner.

United States Tax Court.

Filed June 11, 1985.

Attorney(s) appearing for the Case

Edward G. Lavery and Larry K. Hercules, 13355 Noel Rd., Dallas, Tex., for the petitioners. William D. Hardeman, for the respondent.

Memorandum Opinion

KÖRNER, Judge:

This matter is before the Court on respondent's motion in each case for leave to amend his answer so as to assert the applicability of section 6621 (d),2 as added by section 144 of the Tax Reform Act of 1984, Pub. L. 98-369, 98 Stat. 682.

Section 6621(d) provides for an increase in the interest rate due on underpayments where there...

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