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in the amount of $50,794 and claimed investment tax and business
energy credits totaling $103,362. Respondent disallowed Philip
and Roberta Yarnell's claimed operating loss and credits related
to their investment in Plymouth.
Marvin Yarnell received a B.S. degree from New York
University School of Commerce in 1949. After college, he worked
for 3 years as a sales trainee for a textile company. Then he
became a salesman for Cameo Fabrics and worked for that company
for approximately 11 years. Philip Yarnell graduated from North
Carolina State College with a degree in textile management and
manufacturing. After college he worked for 4 years for a textile
converter company, then started and ran his own business for
approximately 12 years. In 1963, Philip and Marvin Yarnell
formed Yarnell Fabrics, a textile converter corporation.
Both Marvin and Philip Yarnell learned of the Sentinel EPE
recyclers and Plymouth from Bachmann and Abramson.6 Bachmann,
Schwartz had been the accounting firm for Yarnell Fabrics since
the late 1970's. Marvin and Philip Yarnell primarily dealt with
Bachmann, who also advised them on personal financial matters.
Bachmann and Abramson described their trip to PI's plant in
Hyannis and gave the Yarnells copies of the Plymouth offering
memorandum. According to Marvin Yarnell, Bachmann pointed out
6 At the trial, Abramson could not recall a specific meeting
with the Yarnells for purposes of discussing the Plastics
Recycling deal. Marvin Yarnell remembered a meeting at
Bachmann's office whereas Philip Yarnell recalled that the
proposal was introduced when Bachmann and Abramson came to
Yarnell Fabrics.
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