- 18 - 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;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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