- 15 - of the machines, made the popcorn material. Had a very small-barrelled extruder. They ran it through the extruder. And they took the pellets that came out of the extruder and they put it back in the process, which was very difficult to do, by the way, because they used cyclone feeding. So, getting the pellets back in the process wasn't easy. Petitioner observed at the demonstration: "It worked. You know, on the scale that they gave, everything worked." Attorneys from the law firm of Windels, Marx, Davies & Ives (WMDI) visited the PI plant on the same day as petitioner. WMDI prepared the offering memorandum, tax opinion, and other legal documents for all of the 1981 Plastics Recycling partnerships, including Northeast. During a lunch break, petitioner asked the attorneys some questions about the legal aspects of the venture, such as whether the transactions qualified for the recently enacted safe-harbor leasing provisions of section 168(f). Petitioner "knew that the government was not happy with" nonrecourse leveraged lease transactions, and he considered the Northeast transaction to be "a classic leveraged lease deal." After lunch petitioner questioned Bambara, particularly with respect to factors bearing on the price of resin, which he purportedly considered "the crucial part of the economics of this deal". Petitioner understood that PI purchased resin at "a volume discount", but Bambara did not indicate the amount of the discount. Petitioner also learned that because PI received resin shipments by truck instead of rail, it paid a penalty thatPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011