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250 percent of the interest payable with respect to the portion of the
underpayment attributable to negligence.
3In the alternative to the section 6659 addition to tax, respondent
determined an addition to tax under section 6661 for substantial understatement
of liability.
Respondent also determined that interest on the deficiencies
accruing after December 31, 1984, would be calculated at 120
percent of the statutory rate under section 6621(c).
In another two notices of deficiency, respondent determined
deficiencies in the 1982 Federal income taxes of the Kalibans and
the Zimmers in the amount of $204 each, plus additions to tax for
negligence under section 6653(a)(1) in the amount of $10.20 each,
and under section 6653(a)(2) on 50 percent of the interest
payable with respect to $204.3
The parties in each of these cases filed Stipulations of
Settled Issues concerning the adjustments relating to
petitioners' participation in the Plastics Recycling Program.
The stipulations generally provide:4
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 as a result of their participation in the
Plastics Recycling Program.
3 The notices of deficiency for 1982 refer to sec.
6653(a)(1)(A) and (B). During 1982, the additions to tax for
negligence were provided for under sec. 6653(a)(1) and (2).
4 The stipulations of settled issues in the Kaliban cases
(docket Nos. 4252-89 and 27659-89) do not contain the fourth
stipulation. The stipulation of settled issues in the Weber case
(docket No. 10802-89) expressly refers to taxable year 1981.
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