Allan J. and Brenda Becker - Page 14

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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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