Paul L. and Doris J. Triemstra, et al. - Page 4

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          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 the            

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