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$1,202, and under section 6653(a)(2) in amounts equal to 50
percent of the interest due on the respective underpayments
attributable to negligence.
In docket No. 35003-86, respondent also determined
deficiencies for taxable years 1979 and 1980. Those deficiencies
and a portion of the deficiency determined for taxable year 1981
arose from adjustments relating to the Brodies' investment in
Egar Investment Partners, with respect to the Arbitrage Tax
Shelter Management Project. On October 2, 1992, respondent and
the Brodies filed a Stipulation of Settlement of Tax Shelter
Adjustment pertaining to all of the adjustments relating to Egar
Investment Partners. The remaining adjustments in respondent's
notice of deficiency not so settled, and at issue herein, pertain
exclusively to Plymouth Equipment Associates.
Stipulations of Settled Issues concerning petitioners'
respective investments in the Partnerships, and filed in each of
these consolidated cases, 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[4] 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
4 The Stipulation of Settled Issues in docket No. 9915-86
refers to "tax return" in the singular, instead of the plural
"tax returns".
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