- 4 - 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. HisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011