- 8 -- 8 - Petitioners Gollin are limited partners in SAB Reclamation; petitioners Fishbach are limited partners in SAB Recovery and SAB Recycling;2 and petitioners Fredericks are limited partners in SAB Recycling. For convenience, we refer to these partnerships collectively as the Partnerships. The transactions involving the Sentinel EPE Recyclers leased by the Partnerships are substantially identical to those in the Clearwater Group limited partnership (Clearwater), the partnership considered in Provizer v. Commissioner, T.C. Memo. 1992-177. 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 & G Corp. for $1,162,666 each. F & G Corp. then leased the recyclers to Clearwater, which licensed the recyclers to FMEC Corp., which sublicensed them back to PI. The sales of the recyclers from PI to ECI Corp. were financed with nonrecourse notes. Approximately 7 percent of the sales price of the recyclers sold by ECI Corp. to F & G Corp. was paid in cash with the remainder financed through notes. These notes provided that 10 percent of the notes 2 The Fishbachs' interest in SAB Recovery and SAB Recycling was acquired through the law firm in which Myron Fishbach was a named partner during 1981 and 1982, Zimmer, Fishbach & Hertan.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011