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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 than
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