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The parties in each of these consolidated cases filed a
Stipulation of Settled Issues concerning the adjustments relating
to their participation in the Plastics Recycling Program.
Although there are insubstantial differences in the language
used, such as singular terminology versus plural terminology, the
stipulations are substantively identical. The stipulations in
each of these consolidated cases provide, in part:
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
from their participation in the Plastics Recycling
Program, except for the 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).
Long after the trials in these cases, petitioners in docket
Nos. 10147-91 (Selvin), 24512-89 (David), and 19760-89 (Blount)
each filed a Motion For Leave to File Motion for Decision
Ordering Relief From the Negligence Penalty and the Penalty Rate
of Interest and to File Supporting Memorandum of Law under Rule
50. These motions were filed with attached exhibits on September
22, 1995, October 2, 1995, and November 30, 1995, respectively.
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