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rate of interest established under I.R.C. �6621(c),
formerly section 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 I.R.C. Section
6653(a). [See supra note 3.]
Accordingly, the only issues remaining for resolution in these
consolidated cases are: (1) Whether petitioners are liable for
additions to tax under section 6653(a)(1) and (2) for negligence;
and (2) whether petitioners are liable for additions to tax under
section 6659 for underpayments of tax attributable to valuation
overstatements.
FINDINGS OF FACT
Some of the facts have been stipulated in each case and are
so found. The stipulated facts and attached exhibits are
incorporated in the respective cases by this reference. For
convenience, facts unique to each of the individual cases under
consideration are set forth separately at the end of the findings
of fact.
Petitioners Reimann are limited partners in Scarborough
Leasing Associates (Scarborough) and petitioners Brodie and the
Yarnells are limited partners in Plymouth Equipment Associates
(Plymouth). For convenience we refer to these two partnerships
collectively as the Partnerships.
Petitioners have stipulated that the transactions involving
the Sentinel EPE Recyclers leased by the Partnerships are
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