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reply memoranda. For reasons discussed in more detail at the end
of this opinion, and also in Farrell v. Commissioner, T.C. Memo.
1996-295, these motions shall be denied; see also Sann v.
Commissioner, T.C. Memo. 1997-259; Friedman v. Commissioner, T.C.
Memo. 1996-558; Jaroff v. Commissioner, T.C. Memo. 1996-527;
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 section 6653(a)(1) and (2); and (2) whether
petitioners are liable for the additions to tax under section
6659 for underpayments of tax attributable to valuation
overstatements.
FINDINGS OF FACT
Some of the facts have been stipulated in each case and are
so found. The stipulated facts and attached exhibits are
incorporated in the respective cases by this reference.
A. The Plastics Recycling Transactions
These cases concern petitioners' investments in two limited
partnerships that leased Sentinel expanded polyethylene (EPE)
recyclers: Clearwater Group (Clearwater) and Poly Reclamation
Associates (Poly Reclamation). Petitioners Kaliban, Roland, and
Zimmer are limited partners in Poly Reclamation. Petitioners
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