- 3 - determined that interest on deficiencies accruing after December 31, 1984, would be calculated at 120 percent of the statutory rate under section 6621(c) with respect to part of petitioners' underpayment of tax for 1981. Prior to issuance of the May 31, 1989, notice of deficiency, petitioners agreed to an adjustment of losses relating to a partnership not at issue herein, Ethynol Cogeneration Associates. On November 1, 1990, the parties filed a Stipulation settling adjustments contained in the May 31, 1989, notice of deficiency regarding petitioners' interest in Gainesville Associates (Gainesville), a limited partnership.3 On March 7, 1994, the parties filed a Stipulation of Settled Issues with respect to items claimed on petitioners' Federal income tax returns resulting from their participation in the Plastics Recycling Program. The parties stipulated that petitioners are not entitled to any deductions, losses, investment credits, business energy investment credits, or any other tax benefits claimed on 2(...continued) petitioners for the taxable years 1981 and 1982 had not expired on May 31, 1989, the date when respondent mailed the notice of deficiency. 3 Petitioners conceded disallowance of losses claimed in 1981 in the amount of $91,367 and in 1982 in the amount of $89,710, and the additional interest under sec. 6621(c) on the deficiencies arising from the disallowed losses. Respondent conceded all penalties asserted relating to petitioners' investment in Gainesville in 1981 and 1982, except for the sec. 6621(c) additional interest.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011