- 4 - 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 thePage: 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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