Mark Friedman - Page 15

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          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.                                                                     







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