Peter and Ursula Reimann, et al. - Page 4

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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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