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benefits exceeded the amount he invested, and that they were
generated by the purported value of the Sentinel EPE recyclers.
He read the warnings in the offering memorandum that the IRS
would likely audit Plymouth and challenge the value of the
machines. Brodie did nothing to verify the purported value of
the Sentinel EPE recycler and undertook no research into Plymouth
or plastics recycling aside from reviewing the offering
memorandum and speaking with Greene. Although Brodie spoke to
Greene about the investment every few months, he never knew for
sure whether the recyclers were ever delivered to end-users. In
fact, the recyclers were eventually placed with end-users which
did not have sufficient amounts of recyclable plastic scrap
material ever to pay off the notes on the recyclers. Brodie
never made an economic profit in any year from Plymouth. After
he received the tax credits in 1981, however, Brodie was not
concerned that he received no dividends or return of capital with
respect to the Plymouth investment.
3. Marvin and Suzanne Yarnell, Docket No. 3398-92, and Philip
and Roberta Yarnell, Docket No. 13892-92
Petitioners Marvin and Suzanne Yarnell resided in Old
Westbury, New York, when their petition was filed. Petitioners
Philip and Roberta Yarnell resided in Manhasset, New York, when
their petition was filed.
During 1981, Marvin Yarnell was a 75-percent owner and
primary operating executive of Yarnell Fabrics Corporation
(Yarnell Fabrics) and Yarnell Fabrics International, Ltd. (YFIL).
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