Joe E. Henry and Carolyn J.Henry - Page 3

                                        - 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