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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
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