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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 (SAB
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