- 29 - Internal Revenue, Respondent”.14 Subsequently, on February 23, 1994, the Court entered decision in the Whitman case pursuant to the Commissioner’s Motion for Entry of Decision under Rule 248(b). The Court’s decision, which reflected the full concession by Whitman of all items of income, loss, and the underlying valuation used for the Sentinel EPS recyclers for tax credit purposes for 1982 and 1983, completely sustained the Commissioner’s FPAA determinations for those years.15 At no time during the pendency of the proceedings in docket No. 14535-89 did petitioners file with the Court a notice of election to participate in the partnership action pursuant to Rule 245(b). OPINION We have decided many Plastics Recycling cases. Most of those cases have presented issues regarding additions to tax for negligence. See, e.g., Barlow v. Commissioner, T.C. Memo. 2000- 339; Carroll v. Commissioner, T.C. Memo. 2000-184; Ulanoff v. Commissioner, T.C. Memo. 1999-170; Gottsegen v. Commissioner, T.C. Memo. 1997-314; Greene v. Commissioner, T.C. Memo. 1997-296; 14 All of the limited partners of Whitman who had an interest in the outcome of the partnership proceeding were treated as parties to the proceeding. See sec. 6226(c) and (d). See also Title XXIV, Tax Court Rules of Practice and Procedure, regarding partnership actions. 15 Similarly, the Court’s decision completely sustained the Commissioner’s FPAA determinations for 1984 and 1985.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011