Allan J. and Brenda Becker - Page 2

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          A. Statute of Limitations...................................21              
          B. Section 6653(a)--Negligence..............................25              
          C. Section 6659--Valuation Overstatement....................41              
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Norman H. Wolfe pursuant to the provisions of section                 
          7443A(b)(4) and Rules 180, 181, and 183.  All section references            
          are to the Internal Revenue Code in effect for the tax years in             
          issue, unless otherwise indicated.  All Rule references are to              
          the Tax Court Rules of Practice and Procedure.  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:  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 transactions involving the Sentinel recyclers in             
          this case are substantially identical to the transaction                    
          considered in the Provizer case.                                            
               In a notice of deficiency dated September 6, 1989,                     
          respondent determined a deficiency in petitioner Allan J.                   
          Becker's 1982 Federal income tax in the amount of $9,901, and               
          additions to tax for that year in the amount of $527.70 under               






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