- 7 - 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 orPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011