- 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 three notices of deficiency, issued on June 16, 1988, in
docket No. 21518-88 (Sann), on June 6, 1988, in docket No. 21519-
88 (Addington), and on December 22, 1988, in docket No. 4789-89
(Cohn), respondent determined the following deficiencies in and
additions to petitioners' 1981 Federal income taxes:
2 There were three separate trials for these cases. The cases
of John Sann and Marianne Sann, docket Nos. 21518-88 and 22466-
90, were consolidated for the purposes of receiving certain
testimony. The same procedure was followed for the cases of
Laurence M. Addington, docket Nos. 21519-88 and 22399-90, and the
cases of David M. Cohn, docket Nos. 4789-89 and 21209-90.
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