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DEMARTINO v. COMMISSIONER

Docket Nos. 6351-81, 6352-81.

88 T.C. 583 (1987)

ROBERT DEMARTINO AND ELIZABETH DEMARTINO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ROBERT E. MCDONNELL AND ELAINE C. MCDONNELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 12, 1987.

Attorney(s) appearing for the Case

James C. Sherwood, for the petitioners.

Kendall C. Jones and Lawrence M. Hill, for the respondent.

SUPPLEMENTAL OPINION

KÖRNER, Judge:

In the earlier opinion in this matter, DeMartino v. Commissioner, T.C. Memo. 1986-263, we held that the increased interest rate authorized by section 6621(d)1 did not apply to the underpayments determined against petitioners. Section 6621(d) was thereafter amended by section 1535 of the Tax Reform...

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