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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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