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          investigation of the fair market value of the recyclers or of the           
          underlying economic viability or financial structure of SAB Foam.           
          Further, most of petitioner’s professional advisers had a                   
          financial interest in either SAB Foam or another similar                    
          partnership.  The Plastics Recycling transaction was a sham, and,           
          as a sophisticated attorney, petitioner should have been able to            
          figure this out if he really had tried.  Upon consideration of              
          the entire record, respondent’s determinations that petitioners             
          are subject to negligence penalties under section 6653(a)(1) and            
          (2), with respect to their tax return for 1982, are sustained.              
          Issue 2.  Piggyback Agreement                                               
               Petitioners argue that they are entitled to the benefits of            
          the Stipulation of Settlement for Tax Shelter Adjustments                   
          (piggyback agreement) applicable to Plastics Recycling cases.               
          Petitioners claim they are in essentially the same position as              
          the taxpayers in Fisher v. Commissioner, T.C. Memo. 1994-434, and           
          Estate of Satin v. Commissioner, T.C. Memo. 1994-435.                       
          Additionally, petitioners argue that in the stipulation of facts            
          in the present case, “the parties unequivocally stipulated that             
          petitioner agreed to be bound to the lead cases under the                   
          piggyback agreement.  (Supp. Stip., pars. 34-35).”  Respondent              
          disagrees with these arguments, and we agree with respondent.               
               In Fisher and Estate of Satin this Court summarized the                
          background of the piggyback agreement in the Plastics Recycling             
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