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Tax-motivated transactions include "any sham or fraudulent
transaction." Sec. 6621(c)(3)(A)(v).63 We have held that with
respect to the restructuring of the excess value activity,
petitioner engaged in sham transactions lacking in economic
substance. On the basis of the findings set forth herein, and
the fact that the underpayment of tax will exceed $1,000 in 1984,
section 6621(c) is applicable to the underpayment attributable to
those transactions that we have found to be shams. See Price v.
Commissioner, 88 T.C. 860, 888-889 (1987).
Decision will be entered
under Rule 155.
63See supra note 62.
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