- 4 - $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".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