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(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 the addition to tax
under section 6659 for an underpayment of tax attributable to a
valuation overstatement. We hold that they are.
(4) 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. The stipulated facts and attached exhibits are
incorporated herein by this reference. Petitioners resided in
Garden City, New York, at the time that their petition was filed
with the Court.
A. The Recycling Transactions
This case is a part of the Plastics Recycling group of
cases. In particular, the deficiency, additions to tax, and the
additional interest arise from the disallowance of losses,
investment credits, and energy credits claimed by petitioners
with respect to the Clearwater Group partnership (Clearwater).
For a detailed discussion of the transactions involved in
the Plastics Recycling group of cases, see Provizer v.
Commissioner, T.C. Memo. 1992-177, affd. per curiam without
published opinion 996 F.2d 1216 (6th Cir. 1993). The underlying
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