- 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.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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