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21243-85, additions to tax for 1981 in the amount of $7,364 under
section 6659 for valuation overstatement, in the amount of $1,898
under section 6653(a)(1) for negligence, and under section
6653(a)(2) in an amount equal to 50 percent of the interest due
on the underpayment attributable to negligence; and (2) in the
Sorey case, docket No. 7908-89, additions to tax in the amount of
$501 and $19 under section 6653(a) for taxable years 1978 and
1979, respectively.
In her opening brief in docket No. 7908-89, respondent
asserted that Sorey was liable for the addition to tax under
section 6659 for 1981 in the amount of $1,442.60, as opposed to
$3,521.10 as determined in the notice of deficiency. We consider
the section 6659 addition to tax for 1981 asserted in docket No.
7908-89 reduced to correspond to the amount in dispute as set
forth in respondent's opening brief and amend the pleadings to
conform to the proof pursuant to Rule 41(b).
The issues in these consolidated cases are: (1) Whether
expert reports and testimony offered by respondent are admissible
into evidence; (2) whether petitioners are entitled to claimed
deductions and tax credits with respect to Clearwater as passed
through Efron Investors to petitioners; (3) whether petitioners
are liable for additions to tax under section 6653(a)(1) and (2)
for 1981 and whether petitioner Sorey is liable for additions to
tax for negligence or intentional disregard of rules or
regulations under section 6653(a) for 1978 and 1979; (4) whether
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