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substance and a business purpose; (3) sustained the additions to
tax for negligence under section 6653(a)(1) and (2); (4)
sustained the addition to tax for valuation overstatement under
section 6659 because the underpayment of taxes was directly
related to the overvaluation of the Sentinel EPE recyclers; and
(5) held that losses and credits claimed with respect to
Clearwater Group were attributable to tax-motivated transactions
within the meaning of section 6621(c). In reaching the
conclusion that the transaction lacked business purpose, this
Court relied heavily upon the overvaluation of the Sentinel EPE
recyclers.
In Gottsegen v. Commissioner, T.C. Memo. 1997-314, this
Court found that each Sentinel EPS recycler had a fair market
value not in excess of $50,000.
Issue (1) The Underlying Deficiency for 1981
Petitioner contends that he is not liable for the underlying
deficiency for 1981 with respect to his investment in Plymouth.
As already mentioned, petitioner has stipulated substantially the
same facts concerning the underlying transactions as we found in
Provizer v. Commissioner, supra.
The record in the present case regarding the Plymouth
transaction plainly supports respondent's determination regarding
the underlying deficiency. Petitioner has provided no further
evidence nor any novel contention with respect to the underlying
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