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Bear Lake, Minnesota, when they filed the petition in this case.
References to Thornsjo are to petitioner Oreland A. Thornsjo.
References to Woolf are to petitioner Donald L. Woolf.
References to Furlong are to petitioner Lawrence J. Furlong.
A. The Hamilton 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 Hamilton
Recycling Associates (Hamilton 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. per curiam 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.
In a series of simultaneous transactions closely resembling
those in Provizer, that for convenience are referred to herein as
the Hamilton transactions, Packaging Industries Group (PI) of
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