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pellets (or their fair market value if used by the sublicensee),
less the sum of (1) the scrap recycling fee paid to converters
(estimated at 15 cents per pound) and (2) an allowance to
sublicensees for transporting and further processing the recycled
material (also estimated at 15 cents per pound).
In addition to the Clearwater transactions, a number of
other limited partnerships entered into transactions similar to
the Clearwater transactions involving Sentinel EPE recyclers.
B. Individuals Involved
Samuel L. Winer (Winer) is an investor, investment banker,
and consultant. Winer was the general partner of Clearwater and
paid $1,000 for a 1-percent interest in all items of income,
gain, deduction, loss, and credit arising from the operations of
Clearwater. For his services, Winer received $60,000 from the
proceeds of the Clearwater private placement offering.
Richard Roberts (Roberts) was the general partner in a
number of limited partnerships that leased Sentinel EPE
recyclers. Roberts was also a 9-percent shareholder in F&G
Corp., the corporation that leased the recyclers to Clearwater.
From 1982 through 1985, Roberts and Raymond Grant (Grant)
were in the business of promoting tax-sheltered investments.
Grant was the president and 100-percent owner of ECI Corp.
Roberts and Grant together were general partners in other
partnerships. Before the Clearwater transactions, Roberts and
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