Legal Opinion

Provizer v. Commissioner

United States Tax Court

Decided March 25, 1992No. Docket No. 27141-86UnpublishedCited by 12 opinions

During 1981, Ps purchased a second-tier partnership interest in a sale-leaseback transaction structured around plastics recycling equipment. The partnership here is one of a group of plastics recycling transactions which initially had been planned to take advantage of tax credits and deductions. Subsequently, appropriate product and marketing were developed as a framework for the tax and financial design.

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During 1981, Ps purchased a second-tier partnership interest in a sale-leaseback transaction structured around plastics recycling equipment. The partnership here is one of a group of plastics recycling transactions which initially had been planned to take advantage of tax credits and deductions. Subsequently, appropriate product and marketing were developed as a framework for the tax and financial design. The initial transaction planning had been modified in an effort to take advantage of the newly enacted safe-harbor leasing provisions. 1. Held, the transaction here in issue is so lacking in…

1Opinion of the Court

HAROLD M. PROVIZER AND JOAN PROVIZER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Provizer v. Commissioner

Docket No. 27141-86.

United States Tax Court

T.C. Memo 1992-177; 1992 Tax Ct. Memo LEXIS 191; 63 T.C.M. (CCH) 2531; T.C.M. (RIA) 92177;

March 25, 1992, Filed

Decision will be entered for respondent

During 1981, Ps purchased a second-tier partnership interest in a sale-leaseback transaction structured around plastics recycling equipment. The partnership here is one of a group of plastics recycling transactions which initially had been planned to take advantage of tax credits and…

2Cases cited57 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Gregory v. HelveringSupreme Court of the United States · 1935
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Neely v. CommissionerUnited States Tax Court · 1985
  5. Bixby v. CommissionerUnited States Tax Court · 1972

52 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Donald Merino Rosemarie Merino v. Commissioner of Internal Revenue, DefendentsCourt of Appeals for the Third Circuit · 1999
  2. Laurence M. Addington, David M. Cohn, John Sann and Marianne Sann v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
  3. Daniel L. Carroll and Ingrid N. Carroll, Plaintiffs-Appellees-Cross-Appellants v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Second Circuit · 2003
  4. Klein v. United StatesDistrict Court, E.D. Michigan · 1999
  5. Vincent Farrell, Jr. And Clotilde Farrell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998

7 more not listed; retrieve them via the Exa API.

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