Bernice M. and Stanley M. Ulanoff - Page 4




                                        - 4 -                                         

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  The stipulated facts and attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Roslyn Estates, New York, at the time that their petitions were             
          filed with the Court.                                                       
          A.  The Recycling Transactions                                              
               These consolidated cases are part of the Plastics Recycling            
          group of cases.  In particular, the deficiency, additions to tax,           
          and additional interest for 1981 and the additions to tax for               
          1982 through 1984 arise from the disallowance of losses,                    
          investment credits, and energy credits claimed by petitioner with           
          respect to the following two partnerships: (1) For 1981, Plymouth           
          Equipment Associates (Plymouth); and (2) for 1982 through 1984,             
          Taylor Recycling Associates (Taylor).  For convenience, we refer            
          to Plymouth and Taylor collectively as the Partnerships.                    
               For a detailed discussion of the transactions involved in              
          the Plastics Recycling group of cases, see Provizer v.                      
          Commissioner, T.C. Memo. 1992-177, affd. per curiam without                 
          published opinion 996 F.2d 1216 (6th Cir. 1993).  The underlying            
          transactions involving the Sentinel recycling machines                      
          (recyclers) in petitioner's cases are substantially identical to            
          the transactions in Provizer v. Commissioner, supra, and, with              
          the exception of certain facts that we regard as having minimal             
          significance, petitioner has stipulated substantially the same              



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011