- 4 - was filed. Petitioners Sidney and Beverly Cohn resided in Farmington Hills, Michigan, when their petition was filed. During 1981, petitioners Jeffrey Kravitz (Kravitz), Paul Triemstra (Triemstra), and Sidney Cohn (Cohn) were all affiliated with Bromberg, Robinson, Shapero, Cohn & Burgoyne, P.C. (Bromberg, Robinson), a 10 to 14 member law firm in Southfield, Michigan. Kravitz, Triemstra, and Cohn were also general partners in Bellvine Associates (Bellvine) during 1981. Bellvine was a four-man partnership formed to invest in Northeast Resource Recovery Associates (Northeast), a limited partnership. The fourth partner in Bellvine was Michael C. Hechtman (Hechtman), another attorney at Bromberg, Robinson. In 1981, Bellvine acquired a 2.605250-percent interest in Northeast. The underlying deficiencies in these cases resulted from respondent's disallowance of claimed losses and tax credits that were passed through Northeast and Bellvine to petitioners. The facts of the underlying transaction in these cases are substantially identical to those in Provizer v. Commissioner, supra, and may be summarized as follows. In 1981, Packaging Industries, Inc. (PI), manufactured and sold seven Sentinel expanded polyethylene (EPE) recyclers to ECI Corp. for $6,867,000 ($981,000 each), of which $530,000 was paid in cash. ECI Corp., in turn, resold the recyclers to F & G Corp. for $8,138,667 ($1,162,666 each), of which $615,000 was paid in cash. F & G Corp. then leased the recyclers to Northeast, which licensed thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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