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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.
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