- 26 - 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 DiscoverPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011