John Sann and Marianne Sann, et al. - Page 5

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          21518-88 (Sann), respectively.  This Court denied both motions on           
          July 11, 1994.                                                              
               The parties in each of these cases filed substantively                 
          identical Stipulations of Settled Issues concerning the                     
          adjustments relating to petitioners' participation in the                   
          Plastics Recycling Program.  In general, the stipulations                   
               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 �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 negligence under                
               the applicable provisions of �6653(a).                                 
               4.  With respect to the issue of the addition to the                   
               tax under I.R.C. �6659, petitioners do not intend to                   
               contest the value of the Sentinel Recycler or the                      
               existence of a valuation overstatement on the                          
               petitioners' return.  Petitioners, however, reserve the                

          3    The stipulations of settled issues in both of the Cohn                 
          cases, and in the Addington case for 1981, are written in the               
          singular.  Also, the stipulations of settled issues filed in the            
          Cohn cases expressly refer to the sec. 6659 addition to tax as an           
          unresolved issue in the third stipulation.  Finally, the                    
          stipulation of settled issues in the Cohn case for 1982 (docket             
          No. 21209-90) expressly refers to Foam Recycling and Jabrilach              
          Recycling, instead of "the Plastics Recycling Program".                     

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