Estate of Romine C. Hogard, Deceased, James C. Elliott, Personal Representative, and Bill F. Stewart, Personal Representative, and Wanda L. Hogard, et al. - Page 3

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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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