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          limited partners had no right to take part in, or interfere in              
          any manner with, the management or conduct of the business of the           
          Partnerships; (4) there was no established market for the                   
          Sentinel recyclers; and (5) although competitors were purportedly           
          not marketing comparable equipment, and the Sentinel recyclers              
          purportedly involved "carefully guarded trade secrets," PI did              
          "not intend to apply for a patent for protection against                    
          appropriation and use by others."                                           
               In these consolidated cases, the projected tax benefits in             
          the SAB Recovery and SAB Reclamation offering memoranda exceeded            
          petitioner's investments.  According to the offering memoranda,             
          for each $50,000 investor, the projected first-year tax benefits            
          were investment tax credits in the amounts of $82,639 and                   
          $83,712, respectively, plus deductions in the amounts of $40,003            
          and $40,234, respectively.  As a result of petitioner's second-             
          tier, $10,000 investment in SAB Recovery, on their 1981 return              
          petitioners claimed an operating loss in the amount of $7,940 and           
          investment tax and business energy credits totaling $16,508; and            
          on their 1982 return they claimed an operating loss in the amount           
          of $458.  For petitioner's $10,000, second-tier investment in SAB           
          Reclamation in 1982, petitioners claimed an operating loss in the           
          amount of $8,021 and investment tax and business energy credits             
          in the amount of $16,742.                                                   
               Petitioner estimated that at the time he invested in the               
          Partnerships, he was working 70 hours a week at Discover                    
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