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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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