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SAB Resource Recovery Associates and SAB Resource Reclamation
Associates, and that for taxable year 1982 only $104,842 of the
total deficiency is subject to the increased rate of interest
under section 6621(c). We consider the amounts in dispute in
docket Nos. 1643-89 and 618-90 to be adjusted accordingly.
Stipulations of Settled Issues with respect to petitioners'
participation in the Plastics Recycling Program were filed in
each of these consolidated cases. Petitioners each stipulated
the following:3
1. Petitioners are not entitled to any deductions,
losses, investment credits, business energy investment
credits, or any other tax benefits claimed on their tax
returns as a result of their participation in the
Plastics Recycling Program.
2. 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 I.R.C. section
6621(c), formerly section 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 tax for negligence under the
applicable provisions of I.R.C. section 6653(a).
3 Petitioner Snyder's stipulation of settled issues is written
in the singular, and express reference is made to SAB Resource
Recovery Associates and SAB Resource Reclamation Associates,
instead of "the Plastics Recycling Program". In addition,
respondent agreed not to assert the sec. 6661 addition to tax in
the Snyder cases.
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