- 4 - petitioner with respect to a partnership known as Madison Recycling Associates (Madison).7 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 parties have stipulated that the underlying transactions in this case are substantially similar to the transactions in Barlow v. Commissioner, T.C. Memo. 2000-339 (where we found that the underlying transactions at issue were substantially identical to the transactions in Provizer), affd. 301 F.3d 714 (6th Cir. 2002), and Provizer v. Commissioner, supra. In a series of simultaneous transactions, Plastics Industries Group, Inc. (PI), sold8 four Sentinel EPS Recyclers9 7Madison was formed on Oct. 1, 1982, by Richard Roberts (Mr. Roberts), as general partner, and Denise Sausa, as limited partner, and sold 18 limited partnerships at $50,000 per unit. 8Terms such as “sale” and “lease”, as well as their derivatives, are used for convenience only and do not imply that the particular transaction was a sale or lease for Federal tax purposes. Similarly, terms such as “joint venture” and “agreement” are also used for convenience only and do not imply that the particular arrangement was a joint venture or agreement for Federal tax purposes. 9Sentinel EPS Recyclers were used in a process designed to transform scrap polystyrene into resin pellets that could be sold on the open market. Although the transactions in Provizer v. Commissioner, T.C. Memo. 1992-177, affd. per curiam without published opinion 996 F.2d 1216 (6th Cir. 1993), involved Sentinel EPE (expanded polyethylene) Recyclers, the recycling partnerships that leased both the Sentinel EPS and Sentinel EPE Recyclers are (continued...)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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