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After a stipulation by the parties,2 the issues remaining
for decision are as follows:
(1) Whether petitioner Stanley M. Ulanoff (petitioner) is
entitled to (1) a partnership loss and (2) investment and energy
credits for 1981 flowing from the Sentinel EPE recycler leasing
program entered into by Plymouth Equipment Associates. We hold
that he is not.
(2) Whether petitioner is liable for additional interest
under section 6621(c) with respect to the underpayment for 1981.
We hold that he is.
(3) Whether petitioner is liable for additions to tax under
section 6653(a)(1) and (2) for negligence or intentional
disregard of rules or regulations for each of the years in issue.
We hold that he is.
(4) Whether petitioner is liable for the addition to tax
under section 6659 for an underpayment of tax attributable to a
valuation overstatement for each of the years in issue. We hold
that he is.
2 The parties stipulated that pursuant to the provisions of
sec. 6015(b), petitioner Bernice M. Ulanoff is not liable for the
deficiency, additions to tax, and additional interest as
determined by respondent in the notices of deficiency at issue
herein.
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