Jeffrey I. and Roberta H. Stone - Page 3

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          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               
               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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