- 3 -
6621(c); and (4) if we have jurisdiction to decide a taxpayer’s
liability for additional interest under section 6621(c), whether
petitioner is liable for additional interest under section
6621(c).6
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Petitioner resided in Bryn Mawr, Pennsylvania, when
his petition in this case was filed.
The Plastics Recycling Transactions
This case is part of the Plastics Recycling group of cases.
The additions to tax and interest arise from the disallowance of
a loss, an investment credit, and an energy credit claimed by
6Petitioner also claimed in his petition that “The
deficiencies as determined by the Commissioner are in income
taxes for the calendar year 1982 in the amount of $140,388.00 of
which at least $37,500.00 are in dispute.” The $140,388,
however, represents petitioner’s allocable share of the
adjustments respondent made to the items on Madison Recycling
Associates’ (Madison) Federal income tax return for 1982, and the
notice of deficiency reflects only additions to tax under secs.
6653(a)(1) and (2) and 6659 and increased interest under sec.
6621(c). Petitioner did not dispute the $140,388 at trial or on
brief, and we consider this argument abandoned. See Leahy v.
Commissioner, 87 T.C. 56, 73-74 (1986).
Petitioner also claimed in his petition that respondent did
not issue the required notices in connection with the
partnership-level proceeding. See sec. 6223. Petitioner has not
pursued this issue at trial or on brief, and we consider it
abandoned. See Leahy v. Commissioner, supra.
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