- 5 - formerly �6621(d). 3. This stipulation resolves all issues that relate to the items claimed on petitioners' tax returns resulting from their participation in the Plastics Recycling Program, with the exception of petitioners' potential liability for additions to the tax for valuation overstatements under I.R.C. �6659 and for negligence under the applicable provisions of �6653(a). 4. With respect to the issue of the addition to the tax under I.R.C. �6659, petitioners do not intend to contest the issue of the value of the Sentinel Recycler or the existence of a valuation overstatement on the petitioners' returns; however, petitioners reserve their right to contend that the Section 6659 penalty is not applicable in this case. The issues remaining in this case are: (1) Whether the assessments in this case are time-barred; (2) whether petitioners are liable for the additions to tax for negligence under the provisions of section 6653(a); and (3) whether petitioners are liable for additions to tax under section 6659 for underpayments of tax attributable to valuation overstatements. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and attached exhibits are incorporated herein by this reference. A. The Plastics Recycling Transactions This case concerns petitioner Allan J. Becker's investments in two limited partnerships: SAB Resource Recovery Associates (SAB Recovery) and SAB Resource Recycling Associates (SABPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011