- 3 -
7443A(b)(4) and Rules 180, 181, and 183. They were tried and
briefed separately but consolidated for purposes of opinion. All
section references are to the Internal Revenue Code in effect for
the tax years in issue, unless 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 facts of
the underlying transactions and the Sentinel recyclers in these
cases are substantially identical to those in the transaction
considered in the Provizer case.
In notices of deficiency, respondent determined the
following deficiencies in and additions to petitioners' Federal
income taxes:
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011