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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;
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