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A. The Recycling Transactions
This case is part of the Plastics Recycling group of cases.
In particular, the deficiency, additions to tax, and additional
interest arise from the disallowance of a partnership loss
deduction and investment and energy tax credits claimed by
petitioners with respect to petitioner husband's (petitioner)
investment in a partnership known as the Clearwater Group
(Clearwater). Clearwater was one of a large number of plastics
recycling partnerships. On its 1981 partnership return,
Clearwater listed licensing as its principal business and
recycling equipment as its principal product.
For a detailed discussion of the transactions involved in
the Plastics Recycling group of cases, and specifically
Clearwater, see Provizer v. Commissioner, T.C. Memo. 1992-177,
affd. per curiam without published opinion 996 F.2d 1216 (6th
Cir. 1993). The transactions in this case are identical to the
transactions discussed in Provizer as they involve the same
partnership and the same Sentinel EPE recyclers that were
involved in Provizer. Further, with the exception of certain
facts that we regard as having minimal significance, petitioners
have stipulated substantially the same facts concerning the
underlying transactions that were described in Provizer.
However, petitioners were not parties to Provizer and do not
agree to be bound by the decision therein.
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