H. Robert Feinberg - Page 18

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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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