Richard L. and Kathryn Dyckman - Page 5




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          Associates was a limited partner in a partnership known as Taylor           
          Recycling Associates (Taylor).  Taylor was a first-tier TEFRA               
          partnership involved in plastics recycling.  Taylor was involved            
          in a series of transactions similar to those of the Clearwater              
          Group partnership, which was the subject of Provizer v.                     
          Commissioner, T.C. Memo. 1992-177, affd. per curiam without                 
          published opinion 996 F.2d 1216 (6th Cir. 1993).  In Provizer,              
          this Court found that assets valued at $1,162,666 had a fair                
          market value not exceeding $50,000.  The Court also held that the           
          Clearwater Group transactions were a sham and lacked economic               
          substance.                                                                  
               In 1988, a partnership proceeding captioned Taylor Recycling           
          Associates, D L & K Associates, A Partner Other Than the Tax                
          Matters Partner v. Commissioner, docket No. 10184-88 (the Taylor            
          case) was commenced in this Court on behalf of Taylor.  On July             
          21, 1994, the Court entered decision in the Taylor case pursuant            
          to the Commissioner's motion for entry of decision under Rule               
          248(b).  All deductions and credits claimed by Taylor in                    
          connection with its plastics recycling activities were                      
          disallowed.                                                                 
               Pursuant to the Taylor decision, in 1995, respondent                   
          assessed petitioners $9,835 in tax and approximately $40,000 in             
          interest.  Having not heard anything about their investment for             
          approximately 13 years, petitioners were initially convinced that           
          respondent had made a mistake.  Upon learning that they were in             
          fact liable for the assessed amounts pursuant to the Taylor                 

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