Paul L. and Doris J. Triemstra, et al. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  These consolidated cases were assigned to              
          Special Trial Judge Norman H. Wolfe pursuant to the provisions of           
          section 7443A(b)(4) and Rules 180, 181, and 183.2  The Court                
          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 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 transaction in these cases are substantially                 
          identical to those in the Provizer case.                                    
               In notices of deficiency, respondent determined the                    
          following deficiencies in and additions to petitioners' Federal             
          income taxes for the taxable year ending December 31, 1981:                 
                                Additions to Tax                                      
               Docket No.     Petitioners     Deficiency     Sec. 6653(a)(1)    Sec. 6653(a)(2)    Sec. 6659
               14254-89       Triemstra          $13,929           $696                 1            $4,179
               17923-89       Cohn                14,728            736                 1             4,418
               18126-89       Kravitz             10,506            525                 1             3,152
               150 percent of the interest payable with respect to the portion of the 
          underpayment attributable to negligence.                                    
          In the notices of deficiency, respondent also determined that               
          interest on deficiencies accruing after December 31, 1984, would            

               All section references are to the Internal Revenue Code, in            
          effect for the year in issue, unless otherwise stated.  All Rule            
          references are to the Tax Court Rules of Practice and Procedure.            

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