- 18 - 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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