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For convenience, we refer to the series of transactions
among PI, ECI Corp., F & G Corp., each of the Partnerships, FMEC
Corp., and PI as the Partnership transactions. In addition to
the Partnership transactions, a number of other limited
partnerships entered into transactions similar to the Partnership
transactions, also involving Sentinel EPE recyclers and Sentinel
expanded polystyrene (EPS) recyclers. We refer to these
collectively as the Plastics Recycling transactions.
B. The Partnerships
Phoenix and Scarborough are New York limited partnerships
that were formed in late 1981. The general partner of Phoenix is
Richard Roberts (Roberts). He and Samuel L. Winer (Winer) are
the general partners of Scarborough. Winer is also the general
partner of Clearwater, the partnership considered in the Provizer
case. See Provizer v. Commissioner, supra.
SAB Reclamation and SAB Recycling are New York limited
partnerships that were organized and promoted in 1982 by Stuart
Becker (Becker), a certified public accountant (C.P.A.) and the
founder and principal owner of Stuart Becker & Co., P.C. (Becker
Co.), an accounting firm that specialized in tax matters. Becker
organized a total of six recycling partnerships (the SAB
Recycling Partnerships). Two of the SAB Recycling Partnerships
closed in late 1981, two closed in early 1982 (SAB Reclamation
and SAB Recycling), and two more closed in late 1982.
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