Ira S. Greene and Robin C. Greene - Page 8

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               The offering memorandum lists significant business and tax             
          risk factors associated with an investment in Resource.                     
          Specifically, the offering memorandum states:  (1) There is a               
          substantial likelihood of audit by the Internal Revenue Service             
          (IRS), and the purchase price paid by F & G Corp. to ECI Corp.              
          probably will be challenged as being in excess of fair market               
          value; (2) Resource has no prior operating history; (3) the                 
          general partner has no prior experience in marketing recycling or           
          similar equipment; (4) the limited partners have no control over            
          the conduct of Resource's business; (5) there is no established             
          market for the Sentinel EPE recyclers; (6) there are no                     
          assurances that market prices for virgin resin will remain at               
          their current costs per pound or that the recycled pellets will             
          be as marketable as virgin pellets; and (7) certain potential               
          conflicts of interest exist.                                                
               Although the offering memorandum represented that the                  
          Sentinel EPE recycler was a unique machine, it was not.  Several            
          machines capable of densifying low-density materials were already           
          on the market in 1981.  Other plastics recycling machines                   
          available during 1981 ranged in price from $20,000 to $200,000,             
          including the Foremost Densilator, Nelmor/Weiss Densification               
          System (Regenolux), Buss-Condux Plastcompactor, and Cumberland              
          Granulator.  See Provizer v. Commissioner, T.C. Memo. 1992-177.             








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