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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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