Allan J. and Brenda Becker - Page 4

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          would be calculated at 120 percent of the statutory rate under              
          section 6621(c).                                                            
               In her answer, respondent asserted negligence additions to             
          tax for 1979 and 1981, increased additions to tax under sections            
          6653(a)(2) and 6659 for 1982, and a decreased addition to tax               
          under section 6659 for 1981, as follows:                                    
          Year  Sec. 6653(a)  Sec. 6653(a)(1)  Sec. 6653(a)(2)  Sec. 6659             
          1979    $13.10             --               --            --                
          1981      --            $768.85             1           $3,714              
          1982      --               --               1            2,401              
          1    50 percent of the interest due on the amount of the                    
          underpayment attributable to negligence.  Respondent asserted               
          that the amounts of the underpayments attributable to negligence            
          for 1981 and 1982, respectively, were $15,377 and $9,901.                   
          For taxable year 1982, respondent also asserted that the                    
          increased rate of interest under section 6621(c) applied to the             
          entire deficiency for that year.  We consider the amounts in                
          dispute to be adjusted accordingly.                                         
               The parties filed a Stipulation of Settled Issues concerning           
          the adjustments relating to petitioner Allan J. Becker's                    
          participation in the Plastics Recycling Program.  The stipulation           
          provides:                                                                   
               1.  Petitioners are not entitled to any deductions,                    
               losses, investment credits, business energy investment                 
               credits or any other tax benefits claimed on their                     
               1979, 1981 and 1982 returns as a result of their                       
               participation in the Plastics Recycling Program.                       
               2.  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 I.R.C. �6621(c),                    




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