- 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.
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