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colleagues had any specialized knowledge in plastics recycling or
in plastics recycling machines such as the Sentinel EPS
recycler.9
At the time that he signed the subscription agreement and
invested in Dickinson, petitioner did not have any education or
work experience in either plastics materials or plastics
recycling, nor did petitioner have any specialized knowledge
about either the plastics industry in general or the EPS recycler
in particular.
In contrast, at the time that he signed the subscription
agreement, petitioner knew that his investment in Dickinson
offered immediate tax benefits in excess of his $50,000
investment. Petitioner had not previously made any investment
that offered immediate tax benefits in excess of his investment.
Petitioner was influenced to invest in Dickinson by the tax
benefits described in the offering memorandum.
G. Ultimate Finding Regarding Petitioner’s Motivation
Petitioner invested in Dickinson principally because the
investment offered immediate tax benefits in excess of his
investment.
H. Petitioners’ Tax Returns
The tax benefits claimed by petitioners on their Federal
9 There is nothing in the record to suggest that
petitioner’s medical colleagues had any specialized knowledge.
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