Malcolm I. Lewin and Trina Lewin - Page 18

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          gave the same response that he had given concerning SAB Resource.           
          Petitioner discussed the initial results of the SAB Resource                
          transactions with Feinberg, saw the letters of January 14 and               
          June 7, and invested in SAB Foam.                                           
               According to the Schedule K-1 issued by SAB Foam to                    
          petitioners for 1982 and reflected on petitioners’ 1982 Federal             
          income tax return, petitioners invested $12,500 and acquired a              
          1.455882-percent limited partnership interest in SAB Foam’s                 
          profits, losses, and capital.  On their 1982 tax return,                    
          petitioners claimed an ordinary loss of $9,646 from SAB Foam and            
          an investment and energy tax credit of $20,021.  Petitioners had            
          no experience with the plastics materials or the plastics                   
          recycling industry.                                                         
                                       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; Merino v.              
          Commissioner, T.C. Memo. 1997-385, affd. 196 F.3d 147, 151-155              
          (3d Cir. 1999); Greene v. Commissioner, T.C. Memo. 1997-296;                






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