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from our finding of a lack of economic substance. Snyder
conceded that the Partnership transactions were similar to the
Clearwater transaction described in Provizer v. Commissioner,
supra, and we have found that the Partnership transactions lacked
economic substance. Given his concession, and our finding of a
lack of economic substance, and the fact that the records here
plainly show that the overvaluation of the recyclers was the
reason for the disallowance of the tax benefits, we conclude that
the deficiencies caused by the disallowance of the claimed tax
benefits were attributable to the overvaluation of the Sentinel
EPE recyclers.
2. Section 6659(e)
Snyder also contests the imposition of the section 6659
addition to tax on the ground that respondent erroneously failed
to waive the addition to tax. Section 6659(e) authorizes
respondent to waive all or part of the addition to tax for
valuation overstatement if taxpayers establish that there was a
reasonable basis for the adjusted bases or valuations claimed on
the returns and that such claims were made in good faith.
Respondent's refusal to waive a section 6659 addition to tax is
reviewable by this Court for abuse of discretion. Krause v.
Commissioner, 99 T.C. at 179.
Snyder urges that he relied on the offering memoranda,
Becker, and Miller in deciding on the valuation claimed on his
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