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section 6659 for underpayment of tax attributable to valuation
overstatement; and (6) whether petitioner is liable for increased
interest under section 6621(c) for 1981.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated by
this reference. Petitioner resided in Chicago, Illinois, when
his petition was filed. He was a professional football player in
the National Football League and played quarterback for the
Chicago Bears from 1975 through 1984.
Petitioner is a limited partner in EI, which is a limited
partner in the Clearwater limited partnership. The Clearwater
limited partnership is the same recycling partnership that we
considered in Provizer v. Commissioner, supra. The underlying
deficiency for 1981 in this case resulted from respondent's
disallowance of claimed losses and tax credits that were passed
through both Clearwater and EI to petitioner.
Petitioner has stipulated substantially the same facts
concerning the underlying transactions as we found in Provizer v.
Commissioner, supra.3 Those facts may be summarized as follows.
In 1981, Packaging Industries, Inc. (PI), manufactured and sold
3
The parties did not stipulate certain facts concerning the
Provizers, facts regarding the expert opinions, and other matters
that we consider of minimal significance. Although the parties
did not stipulate our findings regarding the expert opinions,
they stipulated our ultimate finding of fact concerning the fair
market value of the recyclers during 1981.
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