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B. Individuals Involved
Richard Roberts (Roberts) was a businessman and the general
partner in a number of limited partnerships that leased Sentinel
EPE recyclers. Roberts was also a 9-percent shareholder in F&G,
the corporation that leased the recyclers to Dickinson in the
Dickinson transactions.
Raymond Grant (Grant) was an investment banker, attorney,
and accountant. Grant was also the president and sole owner of
ECI, the corporation that sold the recyclers to F&G in the
Dickinson transactions.
From 1982 through 1985, Roberts and Grant were in the
business of promoting tax-sheltered investments. Roberts and
Grant also served as general partners in other investments.
Before the Dickinson transactions, Roberts and Grant were clients
of the accounting firm H.W. Freedman & Co. (Freedman & Co.).
Harris W. Freedman (Freedman), a certified public accountant
and the named partner in Freedman & Co., was the president,
chairman of the board, and 9.1 percent owner of F&G. Freedman
was experienced with leveraged leasing, and he owned 94 percent
of a Sentinel EPE recycler.
Freedman & Co. prepared the tax returns for ECI, F&G, and
Clearwater Group, the partnership that was involved in Provizer
v. Commissioner, supra. Although Freedman & Co. did not prepare
the initial financial projections included in the Dickinson
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Last modified: May 25, 2011