Stuart A. and Harriet J. Gollin, et al. - Page 18

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          that in one case he was hired by a major food service company to            
          learn whether a senior financial officer was defrauding the                 
          company.  It was Gollin's job to determine the nature and amount            
          of the fraud and to help in the potential recovery, including               
          recovery negotiations.  Gollin describes himself as "very into              
          investigation and potential scams and the like."                            
               Gollin acquired a 2.25-percent interest in SAB Reclamation             
          for a gross investment of $12,500 in 1982, without taking into              
          consideration any sales commission rebate or advance royalty                
          distribution.  As a result of his investment in SAB Reclamation,            
          on their 1982 Federal income tax return Gollin and his wife                 
          Harriet claimed an operating loss in the amount of $10,025.  Of a           
          total of $20,928 in investment tax and business energy credits              
          flowing from SAB Reclamation, the Gollins claimed $6,391 of the             
          regular investment credit on their 1982 return and carried back             
          the remainder, $4,073, to 1979,3 and they carried back $6,919 of            
          the business energy credit to 1979 and $3,545 to 1980.                      
          Respondent disallowed the Gollins' claimed operating loss and               
          credits related to Gollin's investment in SAB Reclamation.                  
               Gollin learned of the Plastics Recycling transactions and              
          SAB Reclamation in 1981 or 1982 from Becker.  The two had known             


          3    On their 1979 Form 1040X, Amended U.S. Individual Income Tax           
          Return, the Gollins carried back and claimed a total of $4,969 in           
          regular investment credits.  The source of the additional $896 of           
          regular investment credits is unclear from the record in docket             
          No. 16922-90.                                                               




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