- 5 - 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 TaylorPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011