- 2 -
Maureen T. O'Brien, Paul T. Colleran, and David N. Brodsky,
for respondent in docket No. 9915-86.
Maureen T. O'Brien, Paul T. Colleran, Mae J. Lew, Louise
Forbes, and David N. Brodsky, for respondent in docket No. 35003-
86.
Lawrence L. Davidow and Frances Ferrito Regan, for
respondent in docket Nos. 3398-92 and 13892-92.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: These consolidated cases were assigned to
Special Trial Judge Norman H. Wolfe pursuant to the provisions of
section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: These cases are part of the
Plastics Recycling group of cases. For a detailed discussion of
the transactions involved in the Plastics Recycling cases, see
Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without
published opinion 996 F.2d 1216 (6th Cir. 1993). The issues in
these cases involve the leasing of Sentinel expanded polyethylene
2 All section references are to the Internal Revenue Code, in
effect for the year in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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