- 3 - incorporated herein by this reference. Petitioners resided in Lake Stevens, Washington, at the time the petition was filed. A. The Whitman Transactions These 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 known as Whitman Recycling Associates (Whitman). 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. per curiam without published opinion 996 F.2d 1216 (6th Cir. 1993). The parties have stipulated that the underlying transactions involving the Sentinel recycling machines (recyclers) in this case are substantially identical to the transactions in Provizer v. Commissioner, supra. Whitman, a limited partnership, was organized on September 22, 1982. It purported to lease four recyclers manufactured by Packaging Industries (PI) of Hyannis, Massachusetts. On its 1982 Federal income tax return, Whitman reported that each recycler had a basis of $1,750,000, and the partnership reported a net ordinary loss of $713,975.90. The losses and credits reported by Whitman were passed through to petitioners and the other limited partners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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