- 3 - 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 transactions and the Sentinel recyclers in these cases are substantially identical to those considered in the Provizer case. In a notice of deficiency dated July 7, 1988, respondent determined a deficiency in petitioner Friedman's 1981 Federal income tax in the amount of $14,275, plus additions to tax in the amount of $4,283 under section 6659 for valuation overstatement, in the amount of $714 under section 6653(a)(1) for negligence, and under section 6653(a)(2) in the amount of 50 percent of the interest payable with respect to the portion of the underpayment attributable to negligence. Respondent also determined that interest on the deficiency accruing after December 31, 1984, would be calculated at 120 percent of the statutory rate under section 6621(c). In a notice of deficiency dated January 19, 1989, respondent determined a deficiency with respect to the joint Federal income tax return filed by David and Deborah B. Alter (petitioners Alter) for 1981 in the amount of $27,575, plus additions to tax in the amount of $8,272.50 under section 6659 for valuationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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