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DAWSON, Judge: These cases were assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.1 They were tried and
briefed separately but consolidated for purposes of opinion. 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. Through a second tier
partnership, Efron Investors, petitioners David C. Wilson
(Wilson) and Revie Cee Sorey II (Sorey), invested in the
Clearwater Group limited partnership (Clearwater), the same
partnership considered in the Provizer case. Pursuant to
petitioners' requests at trial, this Court took judicial notice
of our opinion in the Provizer case.
By statutory notice of deficiency respondent determined a
deficiency in Wilson's 1981 Federal income tax in the amount of
1
All section references are to the Internal Revenue Code in
effect for the tax years at issue, unless otherwise stated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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