- 11 - Partnership Return of Income, filed by Foam. The FPAA disallowed all deductions and credits claimed by Foam in connection with its plastics recycling activity. On October 25, 1999, respondent issued a notice of deficiency to petitioner for additions to tax for his 1982 taxable year. The additions relate to the deductions and credits petitioner claimed on his original 1982 return with respect to his investment in Foam. Discussion We have decided many Plastics Recycling cases. Most of those cases, like the present case, have presented issues regarding additions to tax for negligence. 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; 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 a few of those cases, we found the taxpayers liable for the additions to tax for negligence. In Provizer v. Commissioner, T.C. Memo. 1992-177, the test case for the Plastics Recycling group of cases, this Court: (1) Found that each recycler had a fair market value of not more thanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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