Anthony J. and Claire L. Pace - Page 4

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               On March 23, 1994, the parties in these cases each filed a             
          Stipulation of Settled Issues.  In each Stipulation of Settled              
          Issues, the parties agreed that petitioners were not entitled to            
          any deductions, investment tax credits, business energy                     
          investment credits, or any other tax benefits claimed on 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 Anthony J. and Claire L. Pace                  
          (petitioners Pace) resided in Lloyd Harbor, New Jersey, when                
          their petition was filed.  Petitioners Edgar P. and Dorothy M.              
          Berry (petitioners Berry) resided in New York, New York, when               
          their petition was filed.                                                   
               During 1981, Anthony J. Pace (petitioner Pace) was an                  
          institutional salesman at Bear Stearns & Co., one of the largest            
          securities brokerage and investment banking organizations in the            




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