Jeffrey H. Weitzman - Page 7




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                    The principal tax benefits expected from an                       
               investment in the Partnership are to be derived from                   
               the Limited Partner’s share of investment and energy                   
               tax credits and tax deductions expected to be generated                
               by the Partnership in 1982.  The tax benefits on a per                 
               Unit basis are as follows:                                             

                                   Projected                                          
                              Regular Investment       Projected Tax                  
                    Payment   and Energy Tax Credits     Deductions                   
               1982   $50,000      $76,736                  $39,878                   
               The Limited partners are not liable for any additional                 
               payment beyond their cash investment for their Units,                  
               nor 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 Windels, Marx, Davies           
          & Ives before leaving in 1982 and forming their own law firm.               
          The opinion letter was addressed to Foam’s general partner and              
          stated that “this letter is intended for your own individual                
          guidance and for the purpose of assisting prospective purchasers            
          and their tax advisors in making their own analysis, and no                 
          prospective purchaser is entitled to rely upon this letter.”  The           
          offering memorandum also emphasized that the opinion provided by            
          Boylan & Evans was for the general partner’s individual guidance            
          and that prospective purchasers were not permitted to rely upon             
          the advice in the opinion.                                                  
               The opinion expressly warned that the investment and energy            
          tax credits available to limited partners would be reduced or               





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