- 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 the
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