- 2 - interest due on a $3,987 deficiency for 1982. The issues are whether petitioner is liable for these additions to tax. Petitioner resided in Boca Raton, Florida, at the time he filed the petition in this case. The facts may be summarized as follows. A. Background This case is part of the Plastics Recycling group of cases. 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. without published opinion 996 F.2d 1216 (6th Cir. 1993). It is stipulated that the underlying transactions involving the Sentinel Recyclers in the present case are substantially identical to the transactions in Provizer v. Commissioner, supra. The facts concerning the transactions as found in Provizer v. Commissioner, supra, are as follows. Packaging Industries Group, Inc. (PI), manufactured and sold six Sentinel Recyclers to Ethynol Cogeneration, Inc. (ECI), for $981,000 each. ECI, in turn, resold the recyclers to F&G Equipment Corp. (F&G Corp.) for $1,162,666 each. F&G Corp. leased the recyclers to the Clearwater Group partnership, which then licensed the recyclers to First Massachusetts Equipment Corp. (FMEC), which sublicensed them back to PI. PI allegedly sublicensed the recyclers to entities (the end-users), which would use them to recycle plastic scrap. The sublicensePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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