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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 sublicense
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