- 6 - On those same dates, each petitioner who filed a motion for leave also lodged with the Court a motion for decision ordering relief from the additions to tax for negligence and the increased rate of interest, with attachments, and a memorandum in support of such motion. Subsequently, respondent filed objections, with attachments, and memoranda in support thereof. For reasons discussed in more detail at the end of this opinion, and also in Farrell v. Commissioner, T.C. Memo. 1996-295, petitioners' motions shall be denied. The issues remaining in these consolidated cases are: (1) Whether the assessment in docket No. 24512-89 (David) is barred by the statute of limitations; (2) whether petitioners are liable for additions to tax under section 6653(a)(1) and (2) for negligence; and (3) whether petitioners are liable for additions to tax under section 6659 for underpayments of tax attributable to valuation overstatement. FINDINGS OF FACT Some of the facts have been stipulated in each case and are so found. The stipulated facts and attached exhibits are incorporated in the respective cases by this reference. A. The Plastics Recycling Transactions These cases concern petitioners' investments in four limited partnerships that leased Sentinel expanded polyethylene (EPE) recyclers: Phoenix Recycling Group (Phoenix), Scarborough Leasing Associates (Scarborough), SAB Resource ReclamationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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