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the consolidated cases herein, raised issues regarding additions
to tax for negligence and valuation overstatement. We have found
the taxpayers liable for such additions to tax in all but one of
the opinions to date on these issues, although procedural rulings
have involved many more favorable results for taxpayers.18
In Provizer v. Commissioner, T.C. Memo. 1992-177, a test
case for the Plastics Recycling group of cases, this Court (1)
found that each Sentinel EPE recycler had a fair market value not
in excess of $50,000, (2) held that the transaction, which is
17(...continued)
Commissioner, T.C. Memo. 1995-181; Eisenberg v. Commissioner,
T.C. Memo. 1995-180.
Greene v. Commissioner, 88 T.C. 376 (1987), concerned the
applicability of the safe-harbor leasing provisions of sec.
168(f)(8). Trost v. Commissioner, 95 T.C. 560 (1990), concerned
a jurisdictional issue. Baratelli v. Commissioner, T.C. Memo.
1994-484; Estate of Satin v. Commissioner, T.C. Memo. 1994-435;
Fisher v. Commissioner, T.C. Memo. 1994-434; Foam Recycling
Associates v. Commissioner, T.C. Memo. 1992-645; Madison
Recycling Associates v. Commissioner, T.C. Memo. 1992-605,
concerned other issues.
18 In Zidanich v. Commissioner, T.C. Memo. 1995-382, we held
the taxpayers liable for the section 6659 addition to tax, but
not liable for the negligence additions to tax under section
6653(a). As indicated in our opinion, the Zidanich case, and the
Steinberg case consolidated with it for opinion, involved
exceptional circumstances.
In Estate of Satin v. Commissioner, supra, and Fisher v.
Commissioner, supra, after the decision in Provizer v.
Commissioner, supra, the taxpayers were allowed to elect to
accept a beneficial settlement because of exceptional
circumstances.
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