Mark Friedman - Page 3

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                         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 valuation                 




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