- 24 - financial projections, which mirrored those made for the Sentinel EPE recycler, petitioner contends that he concluded that he could purchase two Sentinel EPS recyclers and reasonably expect to make a profit. G. Ultimate Finding of Fact At all relevant times, the fair market value of the Sentinel EPE recycler and the Sentinel EPS recycler did not exceed $50,000 per machine. OPINION A. Background We have decided many Plastics Recycling cases. The majority of these cases, like the consolidated cases herein, presented issues regarding additions to tax for negligence and valuation overstatement. See Greene v. Commissioner, T.C. Memo. 1997-296; Kaliban v. Commissioner, T.C. Memo. 1997-271; Sann v. Commissioner, T.C. Memo. 1997-259 n. 13 (and cases cited therein). In Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without published opinion 996 F.2d 1216 (6th Cir. 1993), 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 was almost identical to the transactions in the present cases, was a sham because it lacked economic substance and a business purpose;Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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