- 3 - to petitioner's participation in the Plastics Recycling Program. The stipulation states in pertinent part as follows: 1. Petitioner is not entitled to any deductions, losses, investment credits, business energy investment credits or any other tax benefits claimed on his tax returns as a result of his participation in the Plastics Recycling Program. 2. This stipulation resolves all issues that relate to the items claimed on petitioner's tax returns resulting from his participation in the Plastics Recycling Program with the exception of petitioner's liability for additions to the tax under the applicable provisions of Section 6662(a). After the foregoing stipulation, the issue remaining for decision is whether petitioner is liable for accuracy-related penalties under section 6662(a) for 1989 and 1990. The resolution of this issue turns on whether, for 1989, a substantial valuation misstatement or a substantial understatement of income tax exists for such year, or whether, for 1989 and 1990, petitioner was negligent. FINDINGS OF FACT Some of the facts have been stipulated, and they are so found. Petitioner resided in Bermuda at the time that his petition was filed with the Court. A. The Plastics Transactions The present cases involve petitioner's purchase of a Sentinel expanded polyethylene (EPE) recycler in 1981 and two Sentinel expanded polystyrene (EPS) recyclers in 1982.Page: 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