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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.
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