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for 1982, and reflected on petitioner’s 1982 Federal income tax
return, petitioner invested $12,500 and acquired a 1.455882-
percent limited partnership interest in SAB Foam’s profits,
losses, and capital. On his 1982 tax return, petitioner claimed
an ordinary loss of $9,646 from SAB Foam and an investment and
energy tax credit of $20,382.7 Petitioner later filed a 1982
Form 1040X, Amended U.S. Individual Income Tax Return, dated
December 30, 1986, reversing the deduction of his share of the
operating loss ($9,646) and the investment tax credit ($20,382)
relating to SAB Foam.
OPINION
We have decided many Plastics Recycling cases. Most of
these cases, like the present case, have presented issues
regarding additions to tax for negligence. See, e.g., Weitzman
v. Commissioner, T.C. Memo. 2001-215; Thornsjo v. Commissioner,
T.C. Memo. 2001-129; West v. Commissioner, T.C. Memo. 2000-389;
Barber v. Commissioner, T.C. Memo. 2000-372; Barlow v.
Commissioner, T.C. Memo. 2000-339, affd. 301 F.3d 714 (6th Cir.
2002); 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
7 The parties have stipulated that the amount reported on
petitioner’s 1982 tax return as unadjusted basis of new recovery
property eligible for investment credit was $101,912, which
resulted in a total investment credit of $20,382.
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