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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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