- 3 - 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 for the taxable years in issue as a result of their participation in the Plastics Recycling Program. 2. The petitioners are liable for the additions to tax pursuant to I.R.C. section 6659 as set forth in the notice of deficiency. 3. 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. section 6621(c) as set forth in the notice of deficiency. The issue remaining for decision is whether petitioners are liable for the additions to tax for negligence under section 6653(a) for 1979 and 1980 and under section 6653(a)(1) and (2) for 1981 and 1982. Background Some of the facts have been stipulated, and they are so found. At the time of the filing of the petition, petitioners resided in Tulsa, Oklahoma. References to petitioner are to Joe E. Henry. The details of petitioner's educational background have not been provided. He attended college for at least 1 year and took some accounting courses. He also took various seminars and courses relating to his profession at unspecified locations and times. As of the date of trial, petitioner had been employed in various capacities in manufacturing industries for over 40 years. In the 1970's he was employed as the general manager of severalPage: 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