- 2 - exhibits on November 9, 1995. On the same date, petitioners' motion for decision ordering relief from the negligence penalty and the penalty rate of interest, with attachments, and petitioners' memorandum in support of such motion were lodged with the Court. Subsequently, respondent's objections, with attachments, and memorandum in support thereof, were filed. 1. Background and Procedural Matters This case is part of the Plastics Recycling group of cases. The opinion in the lead case in that group, Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without published opinion 996 F.2d 1216 (6th Cir. 1993), concerning the substance of the transaction and the additions to tax, was filed on March 25, 1992. To date, we have decided more than 25 cases involving various aspects of the Plastics Recycling transactions. Most such cases primarily concern additions to tax for negligence and valuation overstatement. When the present case was tried, on March 31 and April 1, 1994, the opinion in Provizer v. Commissioner, supra, had been issued. Before petitioners filed their motion for leave, more than 12 additional opinions had been filed concerning negligence and valuation overstatement in Plastics Recycling cases. Petitioners base their motion for leave largely upon petitioners' alleged discovery, after the record was closed, of a Stipulation of Settlement between the taxpayers in this case and respondent in a different case for another year. PetitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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