- 15 - the course of his practice, Alter advised his clients whether to consider such investments. Alter acquired a 1.547-percent interest in Poly Reclamation for $12,500 in 1981. As a result of his investment in Poly Reclamation, on their joint 1981 Federal income tax return Alter and his wife Deborah claimed an operating loss in the amount of $9,976, and investment tax and business energy credits totaling $21,584.5 Respondent disallowed the Alters' claimed operating loss and investment tax and business energy credits flowing from Poly Reclamation. Alter learned of the Plastics Recycling transactions from Hirshfield, who in turn had been introduced to the transactions by Winer. Alter understood that Hirshfield previously had done business with Winer and thought well of him. Alter read the Poly Reclamation offering memorandum and attended some meetings with other Shea & Gould partners who were considering an investment in the Plastics Recycling transactions, including Hirshfield, Carroll, Ferraro, Trost, and Parker. He understood that Carroll had a background in engineering, and that Ferraro, who at the time represented British Petroleum, had worked at a plastics 5 Alter and his wife claimed an additional $1,046 in regular investment credits from other qualifying property on their 1981 return.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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