- 3 - Additions to Tax and Increased Interest Sec. Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c) 6661(a) 1979 $2,647 $132 --- --- $794 2 --- 1980 12,047 602 --- --- 3,614 2 --- 1981 6,332 --- $317 1 1,900 2 --- 1982 29,649 --- 1,482 1 7,667 2 $1,023 1 50 percent of the interest due on the deficiency. 2 Interest on the entire deficiency to be computed at 120 percent of the standard underpayment rate. Respondent determined deficiencies, additions to tax, and increased interest with respect to Jerry L. Wilson's Federal income taxes as follows: Additions to Tax and Increased Interest Sec. Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c) 6661(a) 1979 $11,657 $583 --- --- $3,497 2 --- 1980 1,397 70 --- --- 419 2 --- 1982 49,452 --- $2,473 1 12,180 2 $2,213 1 50 percent of the interest due on the deficiency. 2 Interest on the entire deficiency to be computed at 120 percent of the standard underpayment rate. These cases are 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 underlying transactions involving the Sentinel recyclers in this case are substantially identical to the transactions considered in the Provizer case. Consistent with the resolution of some of the disputed issues in Provizer, in each of these cases petitioners filed a Stipulation of Settled Issues concerning the adjustments related to their participation in the Plastics Recycling Program. Each stipulation states:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011