§6660

With this amendment, Congress explicitly sought to overrule our holding in Estate ofYoung and clarify that the Tax Court hasjurisdiction over additions to tax under section 6651(a)(2) "for failure to pay an amount shown on the return where the Tax Court already hasjurisdiction to redetermine a deficiency in tax with respect to that return."3 See H.R.

498, 505-506 (1995) (applying section 6660, which was the precursor of section 6662(g)).

498, 505-506 (1995) (applying section 6660, which was the precursor of section 6662(g)).

Furthermore, we held that petitioner was not liable for an addition to tax for undervaluation pursuant to section 6660.1 We directed the parties to submit computations pursuant to Rule 155.

613 (r riumbering former section 6660 of the Internal Revenue CO e of 1954, stating in part that references to "tax" in the Code include additions to tax- and penalties, and additions to tax and penalt es must be collected in the same manner as' taxes, unless a statü exception applies) .

6660, applicable to returns filed after Dec. 31, 1981. The Tax Equity and Financial Responsibility Act of 1982, Pub. L. 97-248, sec. 323(a), 96 Stat. 324, 613, redesignated sec. 6660 as sec. 6662, applicable to returns the due date (determined without regard to extension) for filing of which was after Dec. 31, 1982. Lastly, the Omnibus Budget

Respondent also determined an addition to tax under section 6660 in the amount of $1,664,396 for 1987.

inafter petitioner) and her husband, Lawrence N. Thompson (hereinafter Mr. Thompson), respondent determined a deficiency in and an addition to the Federal gift tax liability of each of them as follows: Calendar Addition to Tax Year Ended Deficiency Sec. 6660 12/31/88 $398,683.08 $119,605 The adjustment in the respective notices of deficiency was primarily attributable to respondent's determination that the value of gifts of common stock made in the year 1988 was $3,163,500, instead of $1,260,072