Keith E. and Marilyn B. West - Page 6




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               In turn, F&G leased the recyclers to Masters.  Pursuant to             
          the lease and in accordance with applicable provisions of the               
          Internal Revenue Code and Treasury regulations, F&G elected to              
          treat Masters as having purchased the recyclers for purposes of             
          the investment and business energy tax credits.                             
               Simultaneously, Masters entered into a joint venture with PI           
          and Resin Recyclers, Inc. (RRI).  The joint venture agreement               
          provided that RRI was to assist Masters with the placement of               
          recyclers with end-users.  At the same time, PI, ECI, F&G,                  
          Masters, and RRI entered into arrangements that provided that PI            
          would pay a monthly joint venture fee to Masters, in the same               
          amount that Masters would pay as monthly rent to F&G, in the same           
          amount as F&G would pay monthly on its note to ECI, in the same             
          amount that ECI would pay each month on its note to PI.  In                 
          connection with these arrangements, PI, ECI, F&G, Masters, and              
          RRI entered into offsetting agreements so that these monthly                
          payments were kept only as bookkeeping entries and no money                 
          actually was transferred.  Consequently, all of the monthly                 
          payments required among the entities in the above transactions              
          offset each other, and the transactions occurred simultaneously.            
               On its 1982 tax return Masters reported that the four                  
          recyclers had an aggregate basis of $7,000,000, or $1,750,000               
          each, for purposes of the investment and business energy tax                
          credits.  In the present cases, the parties stipulated that in              






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