- 25 - Reclamation on their 1982 return in the amount of $409. Respondent disallowed the Zimmers' claimed operating losses and credits related to Poly Reclamation in full. Zimmer learned of the Plastics Recycling transactions and Poly Reclamation at a meeting with Alter and Feinstein. Alter and Feinstein explained the transactions to him. Zimmer recalled that Alter and/or Feinstein had investigated the Plastics Recycling transactions and PI, and had inspected the recyclers. He understood that the investment would generate additional tax credits because it purportedly saved energy. However, Zimmer could not recall learning about the relationship between the price of oil and the value of the recycled pellets. He was encouraged that Alter and other members of Shea & Gould were investing in a Plastics Recycling transaction. Zimmer never read the Poly Reclamation offering memorandum and never asked to see it. He claims that he expected to receive royalty payments, but he did not independently investigate whether the recycled pellets had any value. When asked if he was aware that the first-year tax benefits would exceed the amount of his investment, Zimmer stated: "I don't know that I was aware of that. Yes, I am now. I knew it had a certain advantage. The monetary, I honestly--it never made any impression upon me. No one--if it was explained to me, it went by me, it went over my head." Zimmer decided to invest in Poly Reclamation based on his meeting with Alter and Feinstein. He recalled receiving progressPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011