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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
2
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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