Leon M. and Mary K. Jaroff - Page 7

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          two limited partnerships that leased Sentinel expanded                      
          polyethylene (EPE) recyclers:  SAB Resource Recovery Associates             
          (SAB Recovery) and SAB Resource Reclamation Associates (SAB                 
          Reclamation).  For convenience, we refer to these two                       
          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           
          were recourse but that the recourse portion of the notes was only           
          due after the nonrecourse portion, 90 percent, was paid in full.            
               All of the monthly payments required among the entities in             




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