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A. The Masters Transactions
These consolidated cases are part of the Plastics Recycling
group of cases. The additions to tax arise from the disallowance
of losses, investment credits, and energy credits claimed by
petitioners with respect to a partnership called Masters
Recycling Associates (Masters or the partnership).
For a detailed discussion of the transactions involved in
the Plastics Recycling cases, see Provizer v. Commissioner, T.C.
Memo. 1992-177, affd. without published opinion 996 F.2d 1216
(6th Cir. 1993). The underlying transactions involving the
Sentinel recycling machines (recyclers) in these 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 significance, petitioners have
stipulated substantially the same facts concerning the underlying
transactions that were described in Provizer v. Commissioner,
supra.
In a series of simultaneous transactions closely resembling
those in Provizer, that for convenience are referred to herein as
the Masters transactions, Packaging Industries Group (PI) of
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