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Form 4549 stated in pertinent part as follows:
Consent to Assessment and Collection - I do not wish
to exercise my appeal rights with the Internal Revenue
Service or to contest in the United States Tax Court
the findings in this report. Therefore, I give my
consent to the immediate assessment and collection of
any increase in tax and penalties, and accept any
decrease in tax and penalties shown above, plus any
interest as provided by law. It is understood that
this report is subject to acceptance by the District
Director.
In November 1982, petitioner invested in a partnership known
as PBB Recycling Associates II (PBB). Petitioner became a
limited partner of PBB, owning a 27.3-percent interest in the
profits, losses, and capital therein. During 1982, PBB was a
limited partner in a partnership known as Taylor Recycling
Associates (Taylor). Taylor was a first-tier TEFRA partnership
involved in plastics recycling. PBB owned a 2.91-percent
interest in the profits, losses, and capital of Taylor.
On his 1982 return, petitioner claimed a net loss and a
business energy investment credit consistent with the 1982
Schedule K-1 that he received from PBB. The propriety of such
loss and credit was not within the scope of Agent Coar's
examination, and Agent Coar did not question either the loss or
the credit during the course of his examination of petitioner's
1982 return.
On February 16, 1988, respondent issued a Notice of Final
Partnership Administrative Adjustment (FPAA) for the taxable year
1982 to the Tax Matters Partner (TMP) of PBB as a partner of
Taylor. Thereafter, a partnership proceeding captioned Taylor
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