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FINDINGS OF FACT3
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 Grosse Pointe Farms, Michigan, at the
time that each of their petitions was filed with the Court.
A. The Dickinson Transactions
These cases are part of the Plastics Recycling group of
cases. In particular, the additions to tax arise from the
disallowance of losses, investment credits, and energy credits
claimed by petitioners with respect to a partnership known as
Dickinson Recycling Associates (Dickinson or the partnership).
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 petitioners’ 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
3 At trial, we deferred ruling on certain evidentiary
objections made by counsel for both parties. Our findings
reflect our action sustaining petitioners’ relevancy objection to
questions regarding Fillmore Land Development and overruling
respondent’s relevancy objection to matters described in sec.
“K.” of our Findings of Fact, infra.
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