Ira S. Greene and Robin C. Greene - Page 4

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               2.  The underpayment in income tax attributable to                     
               petitioner's participation in Resource Reclamation                     
               Associates is a substantial underpayment attributable                  
               to a tax motivated transaction, subject to the                         
               increased rate of interest established under I.R.C.                    
               �6621(c), formerly section 6621(d).                                    
               3.  This stipulation resolves all issues that relate to                
               the items claimed on petitioners' 1981 tax return                      
               resulting from petitioner's participation in Resource                  
               Reclamation Associates, with the exception of                          
               petitioners' potential liability for additions to the                  
               tax for a valuation overstatement under I.R.C. �6659                   
               and for negligence under the applicable provisions of                  
               I.R.C. �6653(a).                                                       
               4.  With respect to the issue of the addition to the                   
               tax under I.R.C. �6659, petitioners do not intend to                   
               contest the issue of the value of the Sentinel Recycler                
               or the existence of a valuation overstatement on the                   
               petitioners' return; however, petitioners preserve                     
               their right to argue that the underpayment in tax is                   
               not attributable to a valuation overstatement within                   
               the meaning of I.R.C. �6659(a)(1), and that even if                    
               I.R.C. �6659 is applicable, the Secretary should have                  
               waived the addition to tax pursuant to the provisions                  
               of I.R.C. �6659(e).                                                    
               The issues remaining in this case are:  (1) Whether                    
          petitioners are liable for the additions to tax for negligence              
          under section 6653(a)(1) and (2); and (2) whether petitioners are           
          liable for the addition to tax under section 6659 for                       
          underpayment of tax attributable to a valuation overstatement.              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and attached exhibits are incorporated                 
          herein by this reference.                                                   







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