- 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.
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