- 35 -- 35 - material in the SAB Recycling offering memorandum describing the structure of the transaction. He testified that he was unaware that F & G Corp.'s evaluators had any conflicts of interest, that Becker was the de facto general partner of SAB Recycling, or that Becker would be receiving a fee as such. Yet the offering memorandum disclosed Becker's ownership of SAB Management, the fees accruing to the general partner, and also explained that Miller was the attorney for and a business associate of Burstein. Fredericks' discussion with Porter, who may have had some insight into plastics and/or plastics recycling, did not address the Sentinel EPE recycler or the Plastics Recycling transactions. In light of petitioners' lack of knowledge about and perfunctory investigations of the Partnership transactions, we find their claim that they reasonably expected an economic profit from the Partnerships unconvincing, even taking into consideration the so- called oil crisis. Moreover, petitioners did not explain how the so-called oil crisis provided a reasonable basis for them to invest in the Partnerships and claim the associated tax deductions and credits. The offering materials warned that there could be no assurances that prices for new resin pellets would remain at their then current level. One of respondent's experts, Steven Grossman, explained that the price of plastics materials is not directly proportional to the price of oil. In his report, he stated that less than 10 percent of crude oil is utilized for making plasticsPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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