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and the Penalty Rate of Interest and To File Supporting
Memorandum of Law under Rule 50. On that same date, petitioners
lodged with the Court a motion for decision seeking relief from
the additions to tax for negligence and the increased rate of
interest, with attachments, and a memorandum in support of the
motion. Subsequently, respondent filed an objection, with
attachments, and a memorandum in support thereof, and petitioners
filed a reply memorandum. For reasons discussed in more detail
at the end of this opinion, and also in Farrell v. Commissioner,
T.C. Memo. 1996-295, petitioners' motion shall be denied. See
also Gollin v. Commissioner, T.C. Memo. 1996-454; 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 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 and are so found.
The stipulated facts and attached exhibits are incorporated
herein by this reference.
A. The Plastics Recycling Transactions
These consolidated cases concern petitioners' investments in
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