Philippe and Nadine Grelsamer - Page 5

                                        - 5 -                                         
          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."            







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