- 2 -
1. The So-Called Oil Crisis..............................21
2. Petitioner's Purported Reliance on an Adviser.........24
3. Miscellaneous.........................................31
4. Conclusion as to Negligence...........................40
B. Section 6659--Valuation Overstatement....................41
1. The Grounds for Petitioners' Underpayments ...........42
2. Concession of the Deficiency..........................47
3. Section 6659(e).......................................50
C. Petitioners' Motion for Leave To File Motion for
Decision Ordering Relief from the Negligence Penalty
and the Penalty Rate of Interest and To File Supporting
Memorandum of Law........................................53
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183. All section references
are to the Internal Revenue Code in effect for the tax year 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: This case is 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 this
case are substantially identical to those considered in the
Provizer case.
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