David C. Wilson - Page 13

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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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