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identical except that petitioner Morgan's is drafted in the
singular because he is the sole petitioner in docket No. 30317-
91. The stipulations provide, in part:
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).
Petitioner Morgan also stipulated that he did not intend to
contest the value of the Sentinel recycler or the existence of a
valuation overstatement on his returns, but reserved his right to
argue that his underpayments were not attributable to a valuation
overstatement and that the section 6659 addition to tax should
have been waived by respondent under section 6659(e). In a
Second Stipulation of Settled Issues, petitioner Morgan and
respondent stipulated that "with respect to the non-plastics
recycling issues for the years in issue, the parties agree to the
adjustments as set forth in the statutory notice of deficiency."
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