- 34 - finding in Provizer that the recyclers had been overvalued was integral to and inseparable from our holding of a lack of economic substance. Petitioners stipulated that the transaction in Masters was substantially similar to the transaction described in Provizer, and that the fair market value of the recyclers in 1982 was not in excess of $50,000. Given those concessions, and the fact that the records here plainly show that the overvaluation of the recyclers was integral to and inseparable from the determination that Masters lacked economic substance, we conclude that the deficiencies were attributable to the overvaluation of the recyclers. For the foregoing reasons, we hold that petitioners are liable for the section 6659 additions to tax for valuation overstatement. To reflect the foregoing, Decisions will be entered for respondent.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34
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