Ira S. Greene and Robin C. Greene - Page 5

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          A.  The Plastics Recycling Transactions                                     
               This case concerns petitioners' investment in Resource                 
          Reclamation Associates (Resource), a limited partnership that               
          leased Sentinel expanded polyethylene (EPE) recyclers.  The                 
          transactions involving the Sentinel EPE recyclers leased by                 
          Resource are substantially identical to those in the Clearwater             
          Group limited partnership (Clearwater), the partnership                     
          considered in Provizer v. Commissioner, supra.  Petitioners have            
          stipulated substantially the same facts concerning the underlying           
          transactions as we found in the Provizer case.                              
               In transactions closely resembling those in the Provizer               
          case, Packaging Industries, Inc. (PI), manufactured and sold                
          seven 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                  
          Resource, 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 sale 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.                







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