- 23 - Respondent’s Affected Items Adjustments On October 6, 2003, respondent issued a notice of deficiency (notice) for 1982 to petitioner. Respondent determined that petitioner was liable for additions to tax under sections 6653(a)(1) and (2) and 6659, and increased interest under section 6621. In the Form 886-A, Explanation of Items, accompanying the notice, respondent explained that he had adjusted petitioner’s reported basis in the recyclers to zero and disallowed the loss and the investment and business energy credits petitioner claimed with respect to Madison pursuant to our decision in docket No. 10601-88. In Form 4549A, Income Tax Examination Changes, accompanying the notice, respondent informed petitioner that the notice reflected only additions to tax. On December 29, 2003, petitioner’s petition disputing respondent’s adjustments, denying that petitioner had acted negligently in the preparation of his tax return or in the valuation of the assets on the underlying return, and denying that he had engaged in a tax-motivated transaction was filed. The resulting case was tried on September 9, 2004, and both parties submitted posttrial briefs. OPINION We have decided many Plastics Recycling cases. Most of these cases, like the present case, raised issues regarding additions to tax for negligence and valuation overstatement.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011