- 6 - 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)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011