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and use by others. The financial structure of the Partnerships
was not clear to petitioner from the offering memoranda, and at
trial he could not recall that the offering memoranda warned that
there was no established market for the recyclers. This point
was discussed in a section of the offering memorandum entitled,
"No Established Market for the Sentinel Recyclers". The offering
memoranda explained that "There is presently no established
market for leasing or licensing the use of the Sentinel Recyclers
or comparable recycling equipment", and that "there can be no
assurance that the Sentinel Recyclers will be placed * * * to any
significant extent". Notwithstanding petitioner's purported
economic profit motive for investing in the Partnerships, the
record in these consolidated cases indicates that petitioners did
not carefully read the offering memoranda, did not give due
consideration to all of the information set out therein, and
ultimately did not place a great deal of reliance, if any, on the
representations therein.
The direct reductions in petitioners' Federal income taxes,
from the investment tax credits alone, ranged from 165 percent to
167 percent of their cash investments, without consideration of
any rebated commissions or advance royalty payments. Therefore,
after adjustments of withholding, estimated tax, or final
payment, like the taxpayers in Provizer v. Commissioner, T.C.
Memo. 1992-177, "except for a few weeks at the beginning,
petitioners never had any money in the * * * [Partnership
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