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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.
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