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Taylor was a first-tier TEFRA partnership. In 1988, a
partnership proceeding captioned Taylor Recycling Associates,
DL&K Associates, A Partner Other Than the Tax Matters Partner v.
Commissioner, docket No. 10184-88 (the Taylor case) was commenced
in this Court in respect of the Taylor transactions. Petitioner
filed a Notice of Election to Participate in the Taylor case in
February 1994. Subsequently, 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. Paragraph 2 of the motion
stated in pertinent part that "Stanley M. Ulanoff agree[s] to the
proposed decision in the [Taylor] case".
B. Individuals Involved
Richard Roberts (Roberts) was the general partner of both
Plymouth and Taylor and owned a 1-percent interest in each
partnership. Roberts was also the general partner in a number of
other limited partnerships that leased and licensed Sentinel
recyclers. He also was a 9-percent shareholder in F&G, the
corporation that leased the recyclers to Plymouth. From 1982
through 1985, Roberts and Raymond Grant (Grant) were in the
business of promoting tax sheltered investments. Grant was the
president and 100-percent owner of ECI. Roberts and Grant
together were general partners in other partnerships. Prior to
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