Thomas E. and Joan A. Bennett - Page 4

                                        - 4 -                                         
          petition, respondent asserted that interest on deficiencies                 
          accruing after December 31, 1984, would be calculated at 120                
          percent of the statutory rate under section 6621(c).  See supra             
          note 3.  In an amendment to answer, respondent asserted an                  
          addition to tax under section 6659 for taxable year 1981.  See              
          supra note 4.                                                               
               Petitioners each filed a Stipulation of Settled Issues                 
          relating to their participation in the "Plastics Recycling                  
          Program" and the additions to tax relating thereto.  The parties            
          stipulated that petitioners Bennett and Black are not entitled to           
          any deductions, losses, investment tax credits, business energy             
          credits, or any other tax benefits claimed on their tax returns             
          as a result of their participation in the "Plastics Recycling               
          Program".  The parties further stipulated that 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 section 6621(c).               
               Respondent and petitioners Bennett also filed a stipulation            
          of settled issues with respect to tax benefits claimed in 1981              
          flowing from their interests in three other limited partnerships            
          not at issue herein:  Ludlow Oil & Gas Drilling Program 1980,               
          Monroe Oil & Gas Drilling Program 1980 Ltd., and Riefenberger No.           
          1 1981 Ltd.                                                                 






Page:  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