- 18 - Plastics Recycling transaction. Becker Co. prepared petitioner's 1981 and 1982 returns and petitioner reviewed them. Petitioner and Becker did not discuss the Partnership transactions in conjunction with the preparation of either return. Petitioner understood that his brother's (Becker) background was tax oriented. Petitioner has no education or work experience in plastics recycling or plastics materials. He never read the SAB Recovery and SAB Recycling offering memoranda. Petitioner did not see a Sentinel recycler prior to investing in the Partnership transactions or otherwise independently investigate the Sentinel recyclers. He did not know when or in what amounts the Partnerships were projected to realize a profit. Petitioner was unaware that Becker, as president and sole shareholder of the general partner of the SAB Recycling partnerships, received substantial fees from the Partnerships. In the end, petitioner knew that the Partnerships leased plastics recyclers, and that his brother, the accountant, claimed the machines were state-of- the-art. Petitioner made little, if any, effort to learn more about the transaction, although he was an experienced businessman and corporate officer. Petitioner never made a profit in any year from his participation in the Partnership transactions. OPINION We have decided a large number of the Plastics RecyclingPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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