Jeffrey I. and Roberta H. Stone - Page 4

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               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 �6653(a).                           
          Respondent's determination of an addition to tax under section              
          6651 with respect to petitioners Cote was not specifically                  
          addressed in the stipulation of settled issues nor elsewhere in             
          the record.  However, given the third stipulation in the                    
          stipulation of settled issues, we consider any issue with respect           
          to the addition to tax under section 6651 to be settled.  See               
          also Rule 142(a).                                                           
               Accordingly, the only issues remaining in these consolidated           
          cases are:  (1) Whether petitioners are liable for additions to             
          tax under section 6653(a)(1) and section 6653(a)(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 and are so found.               
          The stipulated facts and attached exhibits are incorporated by              
          this reference.  Petitioners Stone resided in Framingham,                   
          Massachusetts, when their petition was filed.  Petitioners Cote             
          resided in Huntington, New York, when their petition was filed.             
               During 1981, petitioner Jeffrey Stone (Stone) was the sole             
          owner of an electronics distributor, Stone Component Sales Corp.,           
          for which he worked as a manufacturers' representative.  His                




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