- 6 - FINDINGS OF FACT Some of the facts have been stipulated in each case and are so found. The stipulated facts and attached exhibits are incorporated in the respective cases by this reference. A. The Plastics Recycling Transactions These cases concern petitioners' investments in two limited partnerships that leased Sentinel expanded polyethylene (EPE) recyclers: Clearwater Group (Clearwater) and Poly Reclamation Associates (Poly Reclamation). Petitioner Friedman is a limited partner in Clearwater, and petitioners Alter are limited partners in Poly Reclamation. For convenience, we refer to these partnerships collectively as the Partnerships. The Clearwater partnership, and the transactions involving the Sentinel EPE Recyclers leased by Clearwater, were considered in Provizer v. Commissioner, supra. The transactions involving the Sentinel EPE recyclers leased by Poly Reclamation are substantially identical to the Clearwater transactions. Petitioners have stipulated substantially the same facts concerning the underlying transactions as we found in the Provizer case. In the Provizer case, Packaging Industries, Inc. (PI), manufactured and sold six Sentinel EPE recyclers to ECI Corp. for $981,000 each. ECI Corp., in turn, resold the recyclers to F & GPage: 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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