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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
provide: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 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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