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the section 6659 additions to tax for all years at issue except
1981. Thus, the issues remaining for decision are: (1) Whether
the period for assessment of the additions to tax expired prior
to the issuance of the respective notices of deficiency in this
case;3 (2) whether petitioner is liable for the additions to tax
under section 6653(a)(1) and (2) for each of the years 1979,
1980, 1981, and 1982; and (3) whether petitioner is liable for
the addition to tax under section 6659 for the year 1981.
Some of the facts have been stipulated and are so found.
The stipulation of settled issues, the stipulation of facts, and
the attached exhibits are incorporated herein by reference.
Petitioner resided in Tampa, Florida, when the petition was filed
in this case.
Background
The parties agree that this case is part of a "tax shelter
project" involving plastics recycling machines and that
petitioner, through a partnership, took deductions and credits
relating to recycling machines.
Petitioner is a 1971 graduate of Florida State University.
From her graduation in 1971 through the year 1980, petitioner was
employed in increasingly more responsible positions by Maas
Brothers Department Store (Maas Bros). Petitioner described Maas
3At trial, petitioner in an Amendment to Petition raised as
a defense the period of the statute of limitations.
Concurrently, petitioner filed a motion to dismiss that we
recharacterized as a motion for summary judgment and denied.
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