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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 Recovery and SAB Reclamation are New York limited
partnerships that were organized and promoted in 1981 and 1982,
respectively, 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.
The general partner of each of the SAB Recycling
Partnerships, including SAB Reclamation and SAB Recovery, is SAB
Management Ltd. (SAB Management). SAB Management is wholly owned
5(...continued)
return for 1981 indicates that it leased and licensed at least
seven recyclers. Two statements attached to the return reference
seven recyclers with a fair market value of $8,138,667, but
another attachment references a basis in recyclers of $9,212,401.
The source of the alleged additional basis is unclear from the
record.
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