- 78 -                                         
          overstatement contributed to an underpayment, according to                  
          petitioners, section 6659 cannot apply.  In support of this line            
          of reasoning, petitioners rely heavily upon Heasley v.                      
          Commissioner, 902 F.2d 380 (5th Cir. 1990), and McCrary v.                  
          Commissioner, supra.                                                        
               Petitioners' open-ended concessions do not obviate our                 
          finding that the Partnership transactions lacked economic                   
          substance due to overvaluation of the recyclers.  This is not a             
          situation where we have "to decide difficult valuation questions            
          for no reason other than the application of penalties."  See                
          McCrary v. Commissioner, supra at 854 n.14.  The value of the               
          Sentinel EPE recycler was established in Provizer v.                        
          Commissioner, T.C. Memo. 1992-177, and stipulated by the parties.           
          As a consequence of the inflated value assigned to the recyclers            
          by the Partnerships, petitioners claimed deductions and credits             
          that resulted in underpayments of tax, and we held that the                 
          Partnership transactions lacked economic substance.  Regardless             
          of petitioners' concessions, in these cases the underpayments of            
          tax were attributable to the valuation overstatements.                      
               Moreover, concession of the investment tax credit in and of            
          itself does not relieve taxpayers of liability for the section              
          6659 addition to tax.  See Dybsand v. Commissioner, T.C. Memo.              
          1994-56; Chiechi v. Commissioner, T.C. Memo. 1993-630.  Instead,            
          the ground upon which the investment tax credit is disallowed or            
          conceded is significant.  Dybsand v. Commissioner, supra.  Even             
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