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and other members of his firm prepared the offering memorandum,
tax opinion, and other legal documents for Dickinson. Taggert
owned a 6.66-percent interest in a second-tier Plastics Recycling
partnership.
Robert Gottsegen (Gottsegen) was a businessman active in the
plastics industry and a long-time business associate of Bambara.
Gottsegen was the sole owner of RRI, the corporation that was
involved in the joint venture in the Dickinson transactions, and
a 9.1-percent owner of F&G. Gottsegen was the owner of several
Sentinel recyclers and also the petitioner in Gottsegen v.
Commissioner, T.C. Memo. 1997-314.
Samuel L. Winer (Sam Winer or Winer) was Dickinson’s general
partner and tax matters partner. Winer purportedly paid $1,000
for a 1-percent interest in all items of income, gain, deduction,
loss, and credit of the partnership. For his services, Winer
received $62,000 from the proceeds of the private placement
offering.
C. The Private Offering Memorandum
By a private placement offering memorandum dated October 26,
1982 (the offering memorandum), subscriptions for 18 limited
partnership units in Dickinson were offered by the partnership’s
promoter to potential limited partners at $50,000 per partnership
unit. Pursuant to the offering memorandum, the limited partners
would own 99 percent of Dickinson and the general partner, Winer,
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