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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:
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