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tax for negligence and the increased rate of interest, with
attachments, and a memorandum in support of such motion.
Subsequently, respondent filed objections, with attachments, and
memoranda in support thereof, and petitioners Gollin and Fishbach
thereafter filed reply memoranda. For reasons discussed in more
detail at the end of this opinion, and also in Farrell v.
Commissioner, T.C. Memo. 1996-295, these motions shall be denied.
See also Grelsamer v. Commissioner, T.C. Memo. 1996-399; Zenkel
v. Commissioner, T.C. Memo. 1996-398.
The issues remaining in these consolidated cases are: (1)
Whether petitioners are liable for the additions to tax for
negligence under the provisions of section 6653(a); and (2)
whether petitioners Gollin and Fishbach are liable for additions
to tax under section 6659 for underpayments of tax attributable
to valuation overstatements.
FINDINGS OF FACT
Some of the facts have been stipulated in each case and are
so found. The stipulated facts and attached exhibits are
incorporated in the respective cases by this reference.
A. The Plastics Recycling Transactions
These cases concern petitioners' investments in three
limited partnerships that leased Sentinel expanded polyethylene
(EPE) recyclers: SAB Resource Recovery Associates (SAB
Recovery), SAB Resource Recycling Associates (SAB Recycling), and
SAB Resource Reclamation Associates (SAB Reclamation).
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