- 2 - and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE WOLFE, Special Trial Judge: This case is 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 transaction in this case are substantially identical to those in the Provizer case. In a notice of deficiency dated May 31, 1989, respondent determined a deficiency in petitioners' joint 1981 Federal income tax in the amount of $109,168.19 (in addition to $29,995 previously assessed as a deficiency) and additions to tax for that year in the amount of $41,748.95 under section 6659 for valuation overstatement, in the amount of $6,958 under section 6653(a)(1) for negligence, and under section 6653(a)(2) in an amount equal to 50 percent of the interest due on the underpayment attributable to negligence.2 Respondent also 1(...continued) Procedure. 2 In the May 31, 1989, notice of deficiency, respondent also determined a deficiency in and additions to petitioners' Federal income tax for taxable year 1982. The deficiency and additions to tax determined for 1982 have been settled by the parties and are no longer at issue. Petitioners have conceded that the statute of limitations on the assessment of income tax due from (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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