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After the 1981 SAB Recycling Partnerships closed, Becker had
an accountant sent to PI to confirm, by serial number, that as of
December 31, 1981, the equipment that was leased to the 1981 SAB
Recycling Partnerships was indeed available for use. Becker
arranged for this verification, independent of PI, because he
understood that the investment tax and business energy credits
would not be available if the qualifying property was not
available for use.
Leicht and Tucker also familiarized themselves with the
Plastics Recycling transactions. Leicht has a B.A. degree in
finance and accounting from Penn State University, a J.D. from
SUNY Buffalo, and an LL.M. in taxation from New York University
School of Law. Leicht ran a mathematical check on the numbers
contained in the offering materials for Becker, but he did not
test the underlying assumptions upon which they were based. He
also visited PI in Hyannis and met with Miller and other insiders
to the transactions. Leicht never communicated an opinion as to
the value of the recyclers other than what was presented in the
offering memoranda. He has no education or expertise in plastics
materials or plastics recycling.
E. Petitioners and Their Introduction to the Partnership
Transactions
1. Philippe and Nadine Grelsamer
Petitioners Philippe and Nadine Grelsamer (the Grelsamers)
resided in New York, New York, at the time their petition was
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