Leon and Belle Atkind - Page 4

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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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