- 3 - briefed separately but consolidated for purposes of opinion.2 All section references are to the Internal Revenue Code in effect for the tax years in issue, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE WOLFE, Special Trial Judge: 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 facts of the underlying transactions and the Sentinel recyclers in these cases are substantially identical to those considered in the Provizer case. In four notices of deficiency, respondent determined the following deficiencies in and additions to petitioners' 1981 Federal income taxes: Additions to Tax Petitioners Deficiency 1Sec. 6653(a)(1) 1Sec. 6653(a)(2) Sec. 6659 Kaliban $26,571 $1,328.55 2 3$7,971.30 Roland 27,994 1,399.70 2 38,398.20 Weber 27,642 1,382 2 38,293 Zimmer 27,303 1,365 2 8,191 1Except for the notice of deficiency issued to the Webers, the notices refer to section 6653(a)(1)(A) and (B). During 1981, the additions to tax for negligence were provided for under section 6653(a)(1) and (2). 2 By order dated Mar. 21, 1994, docket Nos. 4252-89 and 27659- 89 (the Kaliban cases) were consolidated for trial, briefing, and opinion. By another order dated Mar. 21, 1994, docket Nos. 10803-89 and 27660-89 (the Zimmer cases) were also consolidated for trial, briefing, and opinion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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