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Equitable Bag Co., a manufacturer of paper and plastic bags.
Canno never saw the recyclers or the pellets and never wrote any
reports assessing the equipment or the pellets. In addition,
Becker retained a law firm, Rabin & Silverman, to assist him in
organizing the SAB Recycling Partnerships. See Spears v.
Commissioner, T.C. Memo. 1996-341, to the effect that in
employing the law firm, Becker sought particularly to protect
himself against liability.
After the 1981 SAB Recycling Partnerships closed, Becker had
an accountant sent to PI to confirm, by serial number, that as of
December 31, 1981, the equipment that was leased to the 1981 SAB
Recycling Partnerships was indeed available for use. Becker
arranged for this verification, independent of PI, because he
understood that the investment tax and business energy credits
would not be available if the qualifying property were not
available for use.
D. Petitioner Allan J. Becker and His Introduction to the
Partnership Transactions
At the time their petition was filed, petitioner Allan J.
Becker resided in Mahwah, New Jersey, and petitioner Brenda
Becker resided in North Ballmer, New York. Petitioners Allan J.
Becker and Brenda Becker were divorced on December 24, 1980.
Brenda Becker did not invest in the Plastics Recycling Program,
and no notice of deficiency has been issued to her for taxable
years 1981 and 1982. The parties stipulated that Brenda Becker
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