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          operating loss (NOL) deductions in the amount of $2,240,458 and             
          $2,200,426, on his 1989 and 1990 income tax returns,                        
          respectively, with respect to his Sentinel EPE and EPS recyclers.           
          The NOL deductions represented carryforwards of NOL's claimed by            
          petitioner for the taxable years 1983 through 1988.                         
          E.   The Notices of Deficiency                                              
               In the notices of deficiency, respondent disallowed all                
          items of loss, deductions, and credits related to the Sentinel              
          recyclers and increased petitioner's income accordingly.                    
               In addition, respondent determined that, for 1989,                     
          petitioner was liable for the accuracy-related penalty under                
          section 6662(a) based on: (1) Negligence; (2) substantial                   
          understatement of income tax liability; and (3) substantial                 
          valuation misstatement.  See sec. 6662(b)(1), (2), and (3).                 
          Respondent also determined that, for 1989 and 1990, petitioner              
          was liable for the accuracy-related penalty based on negligence.            
          See sec. 6662(b)(1).                                                        
               6(...continued)                                                        
          years based on a 5-year recovery period and had therefore already           
          recovered the purported purchase price of those machines; i.e.,             
          $3,500,000.                                                                 
                                                                                     
               Depreciation deductions for petitioner's Sentinel EPS                  
          recyclers served to give rise to, or to increase, net operating             
          losses claimed by petitioner on returns for years prior to those            
          in issue, which net operating losses were carried forward to the            
          years in issue.  In this regard, see the discussion in the text,            
          infra.                                                                      
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