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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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