John Sann and Marianne Sann, et al. - Page 3

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          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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