Thomas E. and Joan A. Bennett - Page 5

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               Respondent's determination of an addition to tax under                 
          section 6661 with respect to petitioners Black was not                      
          specifically addressed in the stipulation of settled issues nor             
          elsewhere in the record.  However, the third stipulation in the             
          stipulation of settled issues provides:                                     
               This stipulation [of settled issues] 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                      
               I.R.C. �6653(a).                                                       
          Because of this stipulation, we consider any issue with respect             
          to the addition to tax under section 6661 to be settled.                    
               The issues for decision in these consolidated cases are:               
          (1) Whether petitioners are liable for additions to tax for                 
          negligence or intentional disregard of rules or regulations under           
          section 6653(a); and (2) whether petitioners are liable for the             
          addition to tax under section 6659 for an underpayment of tax               
          attributable to valuation overstatement.                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and attached exhibits are incorporated by              
          this reference.  Petitioners Bennett resided in Avon,                       
          Connecticut, when their petition was filed.  Petitioners Black              
          resided in New Canaan, Connecticut, when their petition was                 
          filed.                                                                      





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