- 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
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