Stuart A. and Harriet J. Gollin, et al. - Page 3

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          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:                                                               














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