- 3 - 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 consolidated 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 involving the Sentinel recyclers in these consolidated cases are substantially identical to those in the transaction considered in the Provizer case. In a notice of deficiency dated May 24, 1989, respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $8,119, and additions to tax for that year in the amount of $1,985 under section 66592 for valuation overstatement, in the amount of $406 under section 6653(a)(1) for negligence, and under section 6653(a)(1)(B)3 in an amount equal to 50 percent of the interest due on the amount of the underpayment attributable to negligence, $6,619. Respondent also determined that interest on deficiencies accruing after December 2 In the alternative to the sec. 6659 addition to tax, respondent determined an addition to tax under sec. 6661 for substantial understatement of liability. 3 For taxable year 1982, the addition to tax for negligence in an amount equal to 50 percent of the interest due on the amount of the underpayment attributable to negligence was provided for under sec. 6653(a)(2), not sec. 6653(a)(1)(B).Page: 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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