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are they subject to any further assessment.
The offering memorandum also included a tax opinion prepared
by the law firm of Boylan & Evans concerning the tax issues
involved in the Plastics Recycling program. William A. Boylan
and John D. Evans were formerly partners at Windells, Marx, Davis
& Ives before leaving in 1982 and forming their own law firm.
Also included in the offering memorandum were the reports of
two “evaluators”, Samuel Z. Burstein (Burstein) and Stanley
Ulanoff (Ulanoff). Burstein was a professor of mathematics at
New York University. Burstein’s report concluded that the
Sentinel EPS recyclers were capable of continuous recycling. The
report also concluded that the recycling system would yield a
material having commercial value.
At the time Ulanoff prepared his report, he was a professor
of marketing at Baruch College and also the author of numerous
books on technical and marketing subjects. Ulanoff’s report
concluded that the price paid by F&G for the Sentinel EPS
recyclers, the rent paid by Dickinson, and the joint venture
profits were all fair and reasonable.
Burstein owned a 5.82-percent interest in another Plastics
Recycling partnership that leased Sentinel EPS recyclers.
Ulanoff owned interests in other Plastics Recycling partnerships
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