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and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: The present case is part of the
Plastics Recycling group of cases. The issues in this group of
cases center about a six-step transaction involving the sale and
lease of machines designed to recycle plastic scrap. For a
detailed discussion of the transactions involved in the Plastics
Recycling cases, see Provizer v. Commissioner, T.C. Memo. 1992-
177, affd. without published opinion 996 F.2d 1216 (6th Cir.
1993).
This matter is before the Court on participating partners
Ernest C. and Marion K. Karras' (hereinafter participants) Motion
for Special Leave to File Motion for Reconsideration of Decision
or to Vacate Decision filed pursuant to Rules 161 and 162.
Participants also lodged with the Court a Motion For
Reconsideration of Decision or to Vacate Decision. As explained
in greater detail below, we will deny participants' motion for
special leave.
The issue for decision is whether grounds exist in this case
for reopening or vacating what is otherwise a final decision.
Participants allege that the Court lacked subject matter
1(...continued)
effect for the tax years in issue, except as otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
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