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group of cases. Petitioners have clarified the issue by limiting
their claim to the additions to tax under section 6653(a)(1) and
(2). Petitioners further concede that their only argument with
respect to the additions to tax under section 6653 is that they
were denied equal treatment with respect to the settlement offer,
and they do not seek any further proceeding with respect to the
merits under section 6653. An evidentiary hearing in regard to
this motion was held on March 6, 2000.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
New York, New York, when the petition in this case was filed.
References to petitioner in the singular are to petitioner
Michael A. Lacher.
The Plastics Recycling Transaction
In 1981, petitioner acquired a 4.48-percent limited
partnership interest in SAB Resource Recovery Associates (SAB).
SAB is part of the Plastics Recycling group of cases. The
Plastics Recycling group of cases centers about a multistep
transaction involving the sale and lease of machines designed to
recycle plastic scrap. The transactions involving the plastic
recyclers leased by SAB are substantially identical to those in
the Clearwater Group partnership, which was the subject of
Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without
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