Leon and Belle Atkind - Page 3

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            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                             

            petitioners for the taxable years 1981 and 1982 had not expired                             
            on May 31, 1989, the date when respondent mailed the notice of                              
            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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