- 55 - 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 hisPage: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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