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investment tax and business energy credits available to them from
Scarborough. Respondent disallowed the Reimanns' claimed
operating loss and credits related to their investment in
Scarborough.
Reimann received a textile education at the Zurich Textile
School in Zurich, Switzerland, from which he graduated in 1959.
Thereafter he apprenticed in various textile mills in Europe.
Upon finishing his apprenticeships, Reimann returned to the
United States and began working at his father's company, Bernard
Reimann, a supplier of silk fabrics for the tie or neckwear
trade. Bernard Reimann subsequently merged with another fabric
company and became R.B.S., which supplied fabrics to neckwear
manufacturers. Reimann worked first as a stylist and eventually
as an executive salesman at R.B.S. Reimann had no education,
training, or experience in plastics recycling or plastics
machinery.
Reimann learned of Scarborough and the Sentinel EPE
recyclers from Bachmann. Bachmann, Schwartz provided accounting
and financial services to R.B.S. Bachmann typically advised
R.B.S. on financial matters, investments, and major business
decisions. Bachmann and Abramson held a meeting at their offices
to explain the Scarborough partnership transaction and the
Sentinel EPE recyclers. They described their visit to PI's plant
in Hyannis. While Bachmann never quantified the potential
economic profit of the venture, he spoke encouragingly about the
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