- 3 -
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: 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 underlying
transactions in these cases are substantially identical to the
transaction considered in the Provizer case.
In two notices of deficiency, one dated October 27, 1988,
and the other dated October 12, 1989, respondent determined
deficiencies in the 1981 and 1982 Federal income taxes of
petitioner Snyder in the respective amounts of $102,459 and
$118,307, plus an addition to tax for 1982 in the amount of
$26,211 under section 6661 for substantial understatement of tax.
In a notice of deficiency dated October 11, 1988, respondent
determined a deficiency in the joint 1982 Federal income tax of
petitioners Busch in the amount of $52,420. In these three
notices of deficiency, respondent also determined additions to
tax as follows:
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