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several such requests in these consolidated proceedings; these
requests show that Fred and Bruce understand the procedures for
protecting the interests of their clients.
Followed to its logical end, petitioners' quasi-estoppel
argument would yield absurd results. Petitioners' argument,
simply put, is that because they did not protect their interests
for some of the partnerships' later years, respondent has the
responsibility to do so for them under the "doctrine of
consistency". Therefore, petitioners' own failure to file
requests for administrative adjustments would estop respondent
from defending asserted deficiencies or adjustments for the years
properly before the Court. Petitioners have offered no authority
to support an argument so bizarre, and we decline to accept it.
Nevertheless, it is clear that the partnerships' requested
administrative adjustments for some of the income-reporting years
should be granted, as respondent has conceded. If the
transactions are shams for purposes of tax deductions, they are
shams for purposes of reporting taxable income. Sheldon v.
Commissioner, 94 T.C. at 753. "If a transaction is devoid of
economic substance * * * it simply is not recognized for federal
taxation purposes, for better or for worse." Lerman v.
Commissioner, 939 F.2d at 45. Respondent has conceded that, if
we determine the partnerships are shams that are not entitled to
deduct losses for their prior years, it would be appropriate to
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