Daniel L. and Ingrid N. Carroll - Page 4




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          transactions involving the Sentinel recycling machines                      
          (recyclers) in petitioners’ case are identical to the                       
          transactions in Provizer, and, 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 v.                  
          Commissioner, supra.                                                        
               In transactions described in the Provizer case and                     
          stipulated by the parties herein, Packaging Industries of                   
          Hyannis, Massachusetts (PI), manufactured and sold2 six Sentinel            
          EPE3 recyclers to ECI Corporation (ECI) for $981,000 each.  PI              
          manufactures thermoplastic and other types of packaging                     
          machinery, as well as energy saving devices.  PI holds itself out           
          as the world’s largest manufacturer of blister packaging                    
          machinery and as fabricating the industry’s widest line of                  
          thermoforming machinery.  EPE recyclers are batch type machines             
          designed to convert expanded low density polyethylene foam into a           
          densified form called “popcorn” that can be further processed to            
          produce resin pellets suitable for some uses in the plastics                
          industry.                                                                   

               2  Terms such as sale, lease, license, and sublicense, as              
          well as their derivatives, are used for convenience only and do             
          not imply that the particular transaction was in fact a sale,               
          lease, license, or sublicense.                                              
               3  EPE stands for expanded polyethylene.                               





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