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On February 22, 1994, the parties filed a Stipulation of
Settled Issues with respect to petitioners' 1981 Federal income
tax return. The parties stipulated that petitioners are not
entitled to any deductions, losses, investment tax credits,
business energy credits, or any other tax benefits claimed on
their tax returns as a result of their participation in the
"Plastics Recycling Program". The parties further stipulated
that the underpayments in income tax attributable to petitioners'
participation in the "Plastics Recycling Program" are substantial
underpayments attributable to tax motivated transactions, subject
to the increased rate of interest established under section
6621(c).
On March 21, 1994, the parties filed a Partial Stipulation
of Settlement regarding interest income. The parties stipulated
that interest income from accounts with the Irving Trust Co. in
the amount of $1,271, and interest income from Emigrant Savings
Bank account number 2-5054650-4, in the amount of $2,000 is
includable in petitioners' taxable income for tax year 1981. The
parties also stipulated that interest income from Emigrant
Savings Bank account number 2-5054650-4, in the amount of $2,000
2(...continued)
case. For simplicity, we will refer to this section as sec.
6621(c). The annual rate of interest under sec. 6621(c) for
interest accruing after Dec. 31, 1984, equals 120 percent of the
interest payable under sec. 6601 with respect to any substantial
underpayment attributable to tax-motivated transactions.
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