- 4 - 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)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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