Allan J. and Brenda Becker - Page 5

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               formerly �6621(d).                                                     
               3.  This stipulation resolves all issues that relate to                
               the items claimed on petitioners' tax returns resulting                
               from their participation in the Plastics Recycling                     
               Program, with the exception of petitioners' potential                  
               liability for additions to the tax for valuation                       
               overstatements under I.R.C. �6659 and for negligence                   
               under the applicable provisions of �6653(a).                           
               4.  With respect to the issue of the addition to the                   
               tax under I.R.C. �6659, petitioners do not intend to                   
               contest the issue of the value of the Sentinel Recycler                
               or the existence of a valuation overstatement on the                   
               petitioners' returns; however, petitioners reserve                     
               their right to contend that the Section 6659 penalty is                
               not applicable in this case.                                           
               The issues remaining in this case are:  (1) Whether the                
          assessments in this case are time-barred; (2) whether petitioners           
          are liable for the additions to tax for negligence under the                
          provisions of section 6653(a); and (3) whether petitioners are              
          liable for additions to tax under section 6659 for underpayments            
          of tax attributable to valuation overstatements.                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and attached exhibits are incorporated                 
          herein by this reference.                                                   
          A.  The Plastics Recycling Transactions                                     
               This case concerns petitioner Allan J. Becker's investments            
          in two limited partnerships:  SAB Resource Recovery Associates              
          (SAB Recovery) and SAB Resource Recycling Associates (SAB                   








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