- 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 several
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