- 3 -
amounts of $16,941 and $100,472.2 For those same years,
respondent determined the following additions to tax.
Additions to Tax
Year Sec. 6651 Sec. 6653(a)(1)1 Sec. 6653(a)(2) Sec. 6659
1980 $847
1981 $3,619 5,024 2 $30,141
1 For 1980, the addition to tax is under sec. 6653(a).
2 50 percent of the interest payable with respect to the
portion of the underpayment attributable to negligence.
Respondent also determined in each case that interest on
deficiencies accruing after December 31, 1984, would be
calculated at 120 percent of the statutory rate under section
6621(c).
Stipulations of Settled Issues pertaining to petitioners'
respective participation in the Plastics Recycling Program, and
filed in each of these consolidated cases, provide in part that:
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
2 The deficiency in the Cote case for taxable year 1980 is
solely attributable to respondent's disallowance of an investment
credit carryback from taxable year 1981.
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