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overstatement. To the contrary, petitioners stipulated
substantially the same facts concerning the Plymouth transaction
as we found in Provizer v. Commissioner, supra. In the Provizer
case, we held that the taxpayers were liable for the section 6659
addition to tax because the underpayment of taxes was directly
related to the overvaluation of the Sentinel EPE recyclers. The
overvaluation of the recyclers, exceeding 2,325 percent, was an
integral part of our findings in Provizer that the transaction
was a sham and lacked economic substance. Similarly, the record
in this case plainly shows that the overvaluation of the
recyclers is integral to and is the core of our holding that the
Plymouth transaction was a sham and lacked economic substance.
Petitioners' reliance on McCrary v. Commissioner, supra, is
misplaced. In that case, the taxpayers conceded disentitlement
to their claimed tax benefits and the section 6659 addition to
tax was held inapplicable. However, the taxpayers' concession of
the claimed tax benefits, in and of itself, did not preclude
imposition of the section 6659 addition to tax. In McCrary v.
Commissioner, supra, the section 6659 addition to tax was
disallowed because the agreement at issue was conceded to be a
license and not a lease. In contrast, the record in this case
plainly shows that petitioners' underpayment was attributable to
overvaluation of the Sentinel EPE recyclers. We hold that
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