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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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