- 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 NextLast modified: May 25, 2011