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In the spring of 1981, Grant had a discussion with Miller
regarding energy tax credits for recycling equipment. Sometime
after this discussion, petitioner was considering the
installation of energy-saving equipment at one of his companies
and contacted Miller to discuss available tax credits.
Petitioner asked Miller whether PI had any equipment that could
be used to take advantage of tax credits.
Miller contacted Bambara to discuss the idea. Bambara told
Miller about a recycler prototype that Bambara thought might be
suitable for a venture centering around benefits from tax
credits. Miller then arranged for an organizational meeting
including Miller, Bambara, Grant, petitioner, and Anthony
Giovannone, the executive vice president of PI.
At the organization meeting, Bambara discussed the recycling
equipment that PI had developed in response to PI's actual or
potential problems with scrap disposal. Bambara referred to PI's
ability to manufacture recyclers, and he mentioned PI's
proprietary interest in the prototype recycler.
3(...continued)
a safe-harbor lessor and to satisfy the requirements of sec.
168(f). Ultimately, Freedman reduced his ownership interest in
F&G to 9.1 percent, and Grant sold his entire interest. At some
point in time not disclosed in the record, 10 new shareholders
were admitted to F&G, including Miller and petitioner. Miller
and petitioner each have a 9.1 percent ownership interest in F&G.
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