- 3 -
In a first amendment to answer, respondent asserted
additions to tax for negligence for the years 1978, 1979, and
1980 under section 6653(a) in the respective amounts of $25,
$632, and $239,2 and for 1981 under section 6653(a)(1) in the
amount of $1,582, and under section 6653(a)(2) in the amount of
50 percent of the interest due on $31,645. Respondent also
asserted an addition to tax for 1981 under section 6659 for
valuation overstatement in the amount of $6,645.
The parties filed a Stipulation of Settled Issues concerning
the adjustments relating to petitioners' participation in the
Plastics Recycling Program. The stipulation provides:
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.
2. 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. �6621(c),
formerly section 6621(d).
3. This stipulation resolves all issues that relate to
the items claimed on petitioners' tax returns resulting
from their participation in the Plastics Recycling
Program, with the exception of petitioners' potential
liability for additions to the tax for valuation
1(...continued)
accruing after Dec. 31, 1984, equals 120 percent of the interest
payable under sec. 6601 with respect to any substantial
underpayment attributable to tax-motivated transactions.
2 The deficiencies for 1978, 1979, and 1980 derived from
disallowed credit carrybacks from 1981.
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