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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...)
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