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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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