- 8 - Specifically, the offering memoranda state: (1) That there is a substantial likelihood of audit by the Internal Revenue Service (IRS) and that the purchase price paid by F & G Corp. to ECI Corp. probably would be challenged as being in excess of fair market value; (2) that the Partnerships have no prior operating history; (3) that the general partners have no prior experience in marketing recycling or similar equipment; (4) that the limited partners have no control over the conduct of the Partnerships' business; (5) that there is no established market for the Sentinel EPE recyclers; (6) that there are no assurances that market prices for virgin resin will remain at their current costs per pound or that the recycled pellets will be as marketable as virgin pellets; and (7) that certain potential conflicts of interest exist. Petitioners in the cases under consideration do not have any education or work experience in plastics recycling or plastic materials. They did not independently investigate the Sentinel EPE recyclers or see a Sentinel EPE recycler or any other type of plastics recycler prior to participating in the recycling ventures. Petitioners each learned of their respective Partnership transaction from members of the accounting firm Bachmann, Schwartz, and Abramson (Bachmann, Schwartz). Bachmann, Schwartz was formed in 1972 by Donald Bachmann (Bachmann) (deceased prior to trial), a certified public accountant (C.P.A.), William Abramson (Abramson), also a C.P.A., Richard Schwartz and IvanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011