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After a concession by petitioners,2 the issues remaining for
decision are as follows:
(1) Whether petitioners are entitled to a partnership loss
deduction and investment and energy tax credits flowing from the
Sentinel EPE recycler leasing program entered into by the
Clearwater Group. We hold that they are not.
(2) Whether petitioners are liable for additions to tax
under section 6653(a)(1) and (2) for negligence or intentional
disregard of rules or regulations. We hold that they are.
(3) Whether petitioners are liable for additional interest
under section 6621(c). We hold that they are.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found.3 The stipulated facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
White Plains, New York, at the time that their petition was filed
with the Court.
2 Petitioners concede that the Sentinel EPE recyclers that
are involved in this case were overvalued. Petitioners therefore
also concede that they are liable for the addition to tax for
overvaluation under sec. 6659 if we hold that they are liable for
the underlying deficiency.
3 Petitioners objected to many of the stipulated facts on
the ground of relevancy. We have considered petitioners'
objections, and they are overruled.
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