Robert D. and Patricia K. Kaliban, et al. - Page 3

                                                - 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.                                                          

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