- 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
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