Provizer v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
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- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
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