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Warren does not have any experience or education in plastics
or plastics recycling. He did not consult with any experts in
the plastics or plastics recycling industries.
For 1979, 1980, and 1982, Warren and Elizabeth West filed
joint Federal income tax returns. In 1982, Warren invested
$25,000 in Masters. As a result of his investment in Masters,
Warren claimed a net operating loss deduction of $19,615 on his
1982 Federal income tax return. On his 1982 Federal income tax
return, Warren also claimed investment tax and business energy
tax credits totaling $38,502, which was limited to his 1982
income tax liability (as reduced by the partnership loss) and the
alternative minimum tax. On April 18, 1983, Warren filed an
application for tentative refund, Form 1045, carrying back
investment and business energy tax credits to 1979 and 1980 to
generate tax refunds of $19,057, and $3,970, respectively.
OPINION
We have decided many Plastics Recycling cases. Most of
these cases, like the present cases, raised issues regarding
additions to tax for negligence and valuation overstatement.
See, e.g., Barber v. Commissioner, T.C. Memo. 2000-372; 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),
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