- 3 - 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.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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