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attorney was from a reputable law firm, that one of his clients
made some phone calls to investigate the equipment, and that he
thought that Margolin had spoken with Winer.
OPINION
We have decided many Plastics Recycling cases. Most of
these cases, like the present case, have presented issues
regarding additions to tax for negligence. See, e.g., Thornsjo
v. Commissioner, T.C. Memo. 2001-129; West v. Commissioner, T.C.
Memo. 2000-389; Barber v. Commissioner, T.C. Memo. 2000-372;
Barlow v. Commissioner, T.C. Memo. 2000-339; Ulanoff v.
Commissioner, T.C. Memo. 1999-170; Greene v. Commissioner, T.C.
Memo. 1997-296; Kaliban v. Commissioner, T.C. Memo. 1997-271;
Sann v. Commissioner, T.C. Memo. 1997-259 n.13 (and cases cited
therein), affd. sub nom. Addington v. Commissioner, 205 F.3d 54
(2d Cir. 2000). In all but two of the Plastics Recycling cases,
we found the taxpayers liable for the additions to tax for
negligence. Moreover, in all of those cases we found the
taxpayers liable for additions to tax for valuation
overstatement.
In Provizer v. Commissioner, T.C. Memo. 1992-177, the test
case for the Plastics Recycling group of cases, this Court:
(1) Found that each recycler had a fair market value of not more
than $50,000; (2) held that the transaction, which was virtually
identical to the transaction in the present case, was a sham
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