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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
Empire, Plymouth, and Foam are New York limited
partnerships. Empire closed on November 23, 1981; Plymouth
closed on December 21, 1981; and Foam closed on September 22,
1982. Foam is subject to the provisions of the Tax Equity and
Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96
Stat. 324.
Richard Roberts (Roberts) is the general partner of each of
the Partnerships. Roberts also was the Tax Matters Partner (TMP)
for Foam during 1982 and at all other times relevant hereto.
With respect to each of the Partnerships, a private
placement memorandum was distributed to potential limited
partners. Reports by F & G Corp.'s evaluators, Dr. Stanley M.
Ulanoff (Ulanoff), a marketing consultant, and Dr. Samuel Z.
Burstein (Burstein), a mathematics professor, were appended to
the offering memoranda. Ulanoff owns a 1.27-percent interest in
Plymouth and a 4.37-percent interest in Taylor Recycling
Associates. Burstein owns a 2.605-percent interest in Empire and
a 5.82-percent interest in Jefferson Recycling Associates. Like
Empire and Plymouth, Taylor Recycling Associates and Jefferson
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