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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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