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Petitioner concedes that he is liable for an addition to tax
of $5,001 pursuant to section 6659 for an underpayment of tax
attributable to valuation overstatement. The remaining issue for
decision is whether petitioner is liable for additions to tax
pursuant to section 6653(a)(1) and (2) for negligence or
intentional disregard of rules or regulations.
Background
The stipulation of facts and the accompanying exhibits are
incorporated herein by reference. Petitioner resided in New
York, New York, at the time his petition was filed with the
Court.
This case is part of the Plastics Recycling group of cases.
The additions to tax arise from the disallowance of losses,
investment credits, and energy credits claimed by petitioner with
respect to a partnership known as Foam Recycling Associates (Foam
or the partnership).
For a detailed discussion of the transactions involved in
the Plastics Recycling group of cases, see Provizer v.
Commissioner, T.C. Memo. 1992-177, affd. per curiam without
published opinion 996 F.2d 1216 (6th Cir. 1993). The parties
have stipulated that the underlying transactions in petitioner’s
1(...continued)
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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