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shelter was; and Furlong knew that in purchasing a partnership
interest in Hamilton he was buying an interest in a tax shelter.
As a result of his investment in Hamilton, Furlong carried
back to 1979 a net operating loss deduction of $20,361. Furlong
also carried back investment tax and business energy credits that
he had claimed on his 1982 Federal income tax return that were in
excess of his 1982 tax liability. Accordingly, Furlong carried
back a balance of the credits to 1979 to generate a tax refund
claim.
OPINION
We have decided many Plastics Recycling cases. Most of
these cases, like the present case, raised issues regarding
additions to tax for negligence and valuation overstatement.
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; Gottsegen v.
Commissioner, T.C. Memo. 1997-314; 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 two of those cases, we found the
taxpayers liable for the additions to tax for negligence.
Moreover, in all of those cases we found the taxpayers liable for
additions to tax for valuation overstatement.
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