Ira S. Greene and Robin C. Greene - Page 2

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               2. Petitioner's Purported Reliance on Advisers...........21            
               3. Miscellaneous.........................................26            
               4. Conclusion as to Negligence...........................29            
          B. Section 6659--Valuation Overstatement....................30              
               1. Concession of the Deficiency..........................32            
               2. Section 6659(e).......................................36            
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Norman H. Wolfe pursuant to the provisions of section                 
          7443A(b)(4) and Rules 180, 181, and 183.  All section references            
          are to the Internal Revenue Code in effect for the tax year 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:  This case is 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 this              
          case are substantially identical to those considered in the                 
          Provizer case.  In a separate, earlier opinion, this Court denied           
          petitioners' motion for summary judgment.  See Greene v.                    
          Commissioner, 88 T.C. 376 (1987).                                           







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