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reports regarding Poly Reclamation from Alter's office. As he
recalled: "To be honest with you, I didn't pay that much
attention to anything I got but I know that I got very infrequent
reports * * *. It was minuscule."
OPINION
We have decided a large number of the Plastics Recycling
group of cases. Provizer v. Commissioner, T.C. Memo. 1992-177,
affd. without published opinion 996 F.2d 1216 (6th Cir. 1993),
concerned the substance of the partnership transaction and also
the additions to tax. See also Sann v. Commissioner, T.C. Memo
1997-259 and cases cited therein. The majority of these cases,
like the present cases, 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.
In Provizer v. Commissioner, supra, 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 Clearwater transaction was a sham
because it lacked economic substance and a business purpose, (3)
upheld the section 6659 addition to tax for valuation
overstatement since the underpayment of taxes was directly
related to the overstatement of the value of the Sentinel EPE
recyclers, and (4) held that losses and credits claimed with
respect to Clearwater were attributable to tax-motivated
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