- 3 -
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: These consolidated cases are
part of the Plastics Recycling group of cases. For a detailed
discussion of the transactions involved in the Plastics Recycling
cases, see Provizer v. Commissioner, T.C. Memo. 1992-177, affd.
without published opinion 996 F.2d 1216 (6th Cir. 1993). The
facts of the underlying transactions involving the Sentinel
recyclers in these consolidated cases are substantially identical
to those in the transaction considered in the Provizer case.
In a notice of deficiency dated May 24, 1989, respondent
determined a deficiency in petitioners' 1982 Federal income tax
in the amount of $8,119, and additions to tax for that year in
the amount of $1,985 under section 66592 for valuation
overstatement, in the amount of $406 under section 6653(a)(1) for
negligence, and under section 6653(a)(1)(B)3 in an amount equal
to 50 percent of the interest due on the amount of the
underpayment attributable to negligence, $6,619. Respondent also
determined that interest on deficiencies accruing after December
2 In the alternative to the sec. 6659 addition to tax,
respondent determined an addition to tax under sec. 6661 for
substantial understatement of liability.
3 For taxable year 1982, the addition to tax for negligence in
an amount equal to 50 percent of the interest due on the amount
of the underpayment attributable to negligence was provided for
under sec. 6653(a)(2), not sec. 6653(a)(1)(B).
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