Joe E. Henry and Carolyn J.Henry - Page 2

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          references are to the Tax Court Rules of Practice and Procedure.            
          The Court agrees with and adopts the Special Trial Judge's                  
          opinion, which is set forth below.                                          
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               CARLUZZO, Special Trial Judge:  Respondent determined                  
          deficiencies and additions to tax in petitioners' 1979, 1980,               
          1981, and 1982 Federal income taxes as follows:                             
                                             Additions to Tax                         
                   Sec.         Sec.        Sec.         Sec.                        
               Year   Deficiency    6653(a)     6653(a)(1)  6653(a)(2)      6659      
               1979   $15,738.00   $  786.90       ---         ---      $ 4,721.40    
               1980    22,950.00    1,147.50       ---         ---        6,885.00    
               1981    12,645.00      ---       $  632.25       1         3,793.50    
               1982    53,453.70      ---        2,672.69       1        16,036.11    
               1  50 percent of the interest due on the deficiency.                   
          In addition, respondent determined that interest accruing after             
          December 31, 1984, on the deficiency for each year would be                 
          calculated in accordance with section 6621(c).                              
               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).                                                            
               Consistent with the resolution of some of the disputed                 
          issues in Provizer, the parties filed a Stipulation of Settled              
          Issues concerning the adjustments related to petitioners'                   
          participation in the Plastics Recycling Program.  The stipulation           
          provides:                                                                   






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