Bruce and Lois Zenkel, et al. - Page 5

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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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