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recyclers that the Partnerships leased and licensed.5 For
convenience we refer to the series of transactions among PI, ECI
Corp., F & G Corp., each of the Partnerships, FMEC Corp., and PI
as the Partnership transactions. In addition to the Partnership
transactions, a number of other limited partnerships entered into
transactions similar to the Partnership transactions, also
involving Sentinel EPE recyclers and Sentinel expanded
polystyrene recyclers. We refer to these collectively as the
Plastics Recycling transactions.
B. The Partnerships
SAB Recycling and SAB Reclamation are New York limited
partnerships that were organized and promoted in 1982 by Stuart
Becker (Becker), a certified public accountant (C.P.A.) and the
founder and principal owner of Stuart Becker & Co., P.C. (Becker
Co.), an accounting firm that specialized in tax matters. Becker
organized a total of six recycling partnerships (the SAB
recycling partnerships). Two of the SAB recycling partnerships
closed in late 1981, two closed in early 1982, and two more
closed in late 1982.
5 According to the offering memoranda, SAB Reclamation was to
lease and license eight recyclers and SAB Recycling was to lease
and license seven recyclers. However, the SAB Reclamation
partnership tax return for 1982 indicates that it leased and
licensed only four recyclers.
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