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their tax returns as a result of their participation in the
Plastics Recycling Program.
The issues for decision are: (1) Whether petitioners are
liable for additions to tax for negligence or intentional
disregard of rules or regulations under section 6653(a)(1) and
(2); (2) whether petitioners are liable for the addition to tax
under section 6659 for an underpayment of tax attributable to
valuation overstatement; and (3) whether petitioners are liable
for increased interest under section 6621(c).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated by
this reference. Petitioners resided in Clifton, New Jersey, when
their petition was filed.
During 1981, Leon Atkind (petitioner) was an executive with
NBO Stores Inc. (NBO), a discount store chain founded and owned
by him. His spouse, petitioner Belle Atkind, was also employed
as an executive at NBO during that year. On their 1981 Federal
income tax return, petitioners reported gross income from wages,
interest, dividends, capital gains, and other sources in the
amount of $363,705. Consequently, in the absence of significant
deductions or credits, they were subject to payment of Federal
income taxes in substantial amounts for 1981.
In 1981, petitioner acquired a 3.094-percent limited
partnership interest in Hyannis Recycling Associates (Hyannis)
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