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Chicago Bears in 1975, he had less than one semester of study to
complete to earn his degree. In 1993, he received a bachelor of
arts degree in sociology from the University of Illinois. In
addition, at the time of trial, Sorey had earned credit hours in
pursuit of a master's degree in athletic administration and was
the director of the Hammond Boys and Girls Club of Northwest
Indiana.
Petitioners do not have any formal training or work
experience relating to investments. Petitioners do not have any
education or work experience in plastics recycling or plastics
materials. They did not independently investigate the Sentinel
recyclers or see a Sentinel recycler or any other type of plastic
recycler prior to participating in the recycling ventures.
OPINION
In Provizer v. Commissioner, T.C. Memo. 1992-177, a test
case involving the Clearwater transaction and another tier
partnership, this Court (1) found that each Sentinel EPE recycler
had a fair market value not in excess of $50,000, (2) held that
the Clearwater transaction was a sham because it lacked economic
substance and a business purpose, (3) upheld the section 6659
addition to tax for valuation overstatement since the
underpayment of taxes was directly related to the overstatement
of the value of the Sentinel EPE recyclers, and (4) held that
losses and credits claimed with respect to Clearwater were
attributable to tax-motivated transactions within the meaning of
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