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On March 2, 1994, respondent filed a first amendment to
answer in docket No. 19612-90. Respondent asserted therein a
lesser deficiency of $17,445, a lesser addition to tax for
negligence under section 6653(a)(1) in the amount of $872, and an
addition to tax for valuation overstatement under section 6659 in
the amount of $4,132. Respondent also asserted that the interest
under sections 6653(a)(2) and 6621(c) was to be computed on
$17,445 instead of $11,767. In addition, respondent conceded the
addition to tax determined under section 6661.
The parties in these consolidated cases filed Stipulations
of Settled Issues concerning the adjustments relating to their
participation in the Plastics Recycling Program. In docket Nos.
16922-90 (the Gollins) and 19612-90 (the Fishbachs), the
stipulations provide:
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. �6621(c),
formerly �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 the tax for valuation
overstatements under I.R.C. �6659 and for negligence
under the applicable provisions of �6653(a).
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