Oreland A. and Lucille S. Thornsjo - Page 20




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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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