Estate of Ronald Busch, Deceased, Rochelle Busch, Executrix and Rochelle Busch, et al. - Page 6

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          In addition, petitioners Busch conceded their liability for the             
          section 6659 addition to tax.  With respect to petitioners Busch,           
          in her trial memorandum respondent reduced the addition to tax              
          under section 6659 to $12,557.  The Stipulation of Settled Issues           
          does not indicate the final settled amount.  Petitioner Snyder              
          agreed not to contest the value of the Sentinel EPE recycler and            
          conceded the existence of a valuation overstatement on his                  
          returns, but preserved his right to contest the issue of whether            
          respondent should have waived the addition to tax under the                 
          provisions of section 6659(e).                                              
               The issues in these consolidated cases are:  (1) Whether               
          petitioners are liable for additions to tax under section                   
          6653(a)(1) and (2); and (2) whether petitioner Snyder is liable             
          for the addition to tax under section 6659 for underpayments of             
          tax attributable to valuation overstatements.  Snyder's counsel             
          raised a statute of limitations issue but specifically conceded             
          that issue in their reply brief.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated in each case and are            
          so found.  The stipulated facts and attached exhibits are                   
          incorporated in the respective cases by this reference.                     
          A.  The Plastics Recycling Transactions                                     
               These cases concern petitioners' investments in two limited            
          partnerships that leased Sentinel expanded polyethylene (EPE)               
          recyclers:  SAB Resource Reclamation Associates (SAB Reclamation)           




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