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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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Last modified: May 25, 2011