Daniel L. and Ingrid N. Carroll - Page 2




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          and adopts the opinion of the Special Trial Judge, which is set             
          forth below.                                                                
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
          ARMEN, Special Trial Judge:  Respondent determined a                        
          deficiency with respect to petitioners' Federal income tax for              
          1981 in the amount of $26,639, as well as additions to tax under            
          section 6659 in the amount of $7,992, under section 6653(a)(1) in           
          the amount of $1,344, and under section 6653(a)(2) in the amount            
          of 50 percent of the portion of the underpayment that is                    
          attributable to negligence.  Respondent also determined that                
          petitioners are liable for additional interest under section                
          6621(c) for interest on the entire underpayment to be computed at           
          120 percent of the rate otherwise applicable under section                  
          6621(a).                                                                    
               The issues for decision are as follows:                                
               (1) Whether petitioners are entitled to a partnership loss             
          and investment and energy credits flowing from the Sentinel EPE             
          recycler leasing program entered into by Clearwater Group.  We              
          hold that they are not.                                                     





          (...continued)                                                              
          references are to the Internal Revenue Code in effect for the               
          taxable year in issue, and all Rule references are to the Tax               
          Court Rules of Practice and Procedure.                                      





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