Robert Gottsegen - Page 2

                                        - 2 -                                         
          The Court agrees with and adopts the opinion of the Special Trial           
          Judge, which is set forth below.                                            
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
          ARMEN, Special Trial Judge:  Respondent determined                          
          deficiencies and accuracy-related penalties with respect to                 
          petitioner's Federal income taxes for the years and in the                  
          amounts as shown below:                                                     
                                             Accuracy-related penalty                 
               Year      Deficiency          Sec. 6662(a)                             
               1989      $34,823                  $6,965                              
               1990      1,196                    239                                 
               The present cases are a part of the Plastics Recycling group           
          of cases.  For a detailed discussion of the transactions involved           
          in the Plastics Recycling group of cases, see Provizer v.                   
          Commissioner, T.C. Memo. 1992-177, affd. without published                  
          opinion 996 F.2d 1216 (6th Cir. 1993).  The underlying                      
          transactions involving the Sentinel recyclers in the present                
          cases are substantially identical to the transactions in Provizer           
          v. Commissioner, supra.                                                     
               Consistent with the resolution of some of the disputed                 
          issues in Provizer v. Commissioner, supra, the parties filed a              
          Stipulation of Settled Issues concerning the adjustments related            



          (...continued)                                                              
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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