- 11 - On October 7, 1981, in a series of transactions similar to those of the Clearwater Group partnership in Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without published opinion 996 F.2d 1216 (6th Cir. 1993), petitioner purchased outright one Sentinel EPE recycler from ECI Corp. for $1,162,667.4 As prearranged, petitioner leased the recycler to FMEC Corp. Thus, the significant transactions of petitioner's purchase of the Sentinel EPE recycler differ from the underlying transactions in Provizer in the following respects: (1) The form of petitioner's interest in the equipment; (2) the entity from which petitioner's interest was obtained; (3) the fact that equipment was leased, rather than licensed, to FMEC Corp.; and (4) the number of machines sold, leased, licensed, and sublicensed. As of October 7, 1981, there was no established market for operating Sentinel EPE recyclers. Petitioner never made a profit in any year from his Sentinel EPE recycler. 2. Petitioner's Purchase of the Sentinel EPS Recyclers In 1982, PI manufactured Sentinel EPS recyclers which recycled expanded polystyrene. Bambara showed petitioner the blueprints of the machine and explained to petitioner that the 4 Petitioner purchased the Sentinel EPE recycler for cash in the amount of $43,700 and notes in the amount of $1,118,967. It does not appear that petitioner made any payments on the note.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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