Jeffrey H. Weitzman - Page 11




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          Partnership Return of Income, filed by Foam.  The FPAA disallowed           
          all deductions and credits claimed by Foam in connection with its           
          plastics recycling activity.                                                
               On October 25, 1999, respondent issued a notice of                     
          deficiency to petitioner for additions to tax for his 1982                  
          taxable year.  The additions relate to the deductions and credits           
          petitioner claimed on his original 1982 return with respect to              
          his investment in Foam.                                                     
                                    Discussion                                       
               We have decided many Plastics Recycling cases.  Most of                
          those cases, like the present case, have presented issues                   
          regarding additions to tax for negligence.  See, e.g., West v.              
          Commissioner, T.C. Memo. 2000-389; Barber v. Commissioner, T.C.             
          Memo. 2000-372; Barlow v. Commissioner, T.C. Memo. 2000-339;                
          Carroll v. Commissioner, T.C. Memo. 2000-184; Ulanoff v.                    
          Commissioner, T.C. Memo. 1999-170; Greene v. Commissioner, T.C.             
          Memo. 1997-296; Kaliban v. Commissioner, T.C. Memo. 1997-271;               
          Sann v. Commissioner, T.C. Memo. 1997-259 n.13 (and cases cited             
          therein), affd. sub nom. Addington v. Commissioner, 205 F.3d 54             
          (2d Cir. 2000).  In all but a few of those cases, we found the              
          taxpayers liable for the additions to tax for negligence.                   
               In Provizer v. Commissioner, T.C. Memo. 1992-177, the test             
          case for the Plastics Recycling group of cases, this Court:  (1)            
          Found that each recycler had a fair market value of not more than           






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