- 23 - Nielsen v. Commissioner, 87 T.C. 779 (1986). Therefore, if the addition to tax is appropriate, it would apply to all the years before us. Here, respondent asserts an overstatement exceeding 250 percent of the value of the four Sentinel EPS Recyclers on the partnership return. Petitioners do not contest the value was overstated as respondent asserts, but petitioners maintain that the adjustment in question was not specifically tied to the value of the recyclers. Nevertheless, the FPAA notes the disallowance of $7 million in investment tax credit property and $7 million in business energy investment credit property. Ultimately, these adjustments were sustained. Petitioners understandably make no attempt to offer a reasonable basis for the value claimed on the partnership return under section 6659(e). Given these circumstances, we reject petitioners’ argument and sustain the addition to tax under section 6659 as determined by respondent. To reflect the foregoing and concessions by the parties, Decision will be entered under Rule 155.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23Last modified: November 10, 2007