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from the Clearwater investment in the total amount of $22,303.
The tax credits were based on valuing a Sentinel EPE recycler at
$1,162,667. The Schedule E partnership loss and the investment
and energy tax credits served to reduce petitioners' income tax
liability on their 1981 return by $28,169, an amount more than
twice their $12,500 investment in Clearwater.
In the notice of deficiency, respondent disallowed the
Schedule E partnership loss and the investment and energy tax
credits claimed by petitioners on their 1981 return with respect
to the Clearwater investment.
ULTIMATE FINDING OF FACT
At all relevant times, the fair market value of the Sentinel
EPE recyclers did not exceed $50,000 per machine.
OPINION
We have decided many Plastics Recycling cases. Most of
these cases, like the present case, presented issues regarding
additions to tax for negligence and valuation overstatement. See
Greene v. Commissioner, T.C. Memo. 1997-296; Kaliban v.
Commissioner, T.C. Memo. 1997-271; Sann v. Commissioner, T.C.
Memo. 1997-259 n.13 (and cases cited therein). We found the
taxpayers liable for the addition to tax for valuation
overstatement in all of those cases and liable for the additions
to tax for negligence in all but two of those cases. In a
limited number of cases, the taxpayers also contested the
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