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$1,750,000 for each recycler. Petitioner concedes that the fair
market value of a recycler in 1982 was not in excess of $50,000.
Therefore, if petitioner’s underpayment of tax is attributable to
such valuation overstatement, petitioner is liable for the
section 6659 addition to tax at the rate of 30 percent of the
underpayment of tax attributable to the tax benefits claimed with
respect to the partnership.
Except for his petition, petitioner makes no argument
concerning the section 6659 addition to tax. It is clear that
the underpayment of tax resulted directly from the grossly
overstated value of the recycling machinery. Respondent’s
determination with respect to the section 6659 addition to tax is
sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011