- 16 - the partnership tax return; and (3) increased SAB Foam’s “other income” by $5,626. Subsequently, SAB Foam’s TMP filed a petition with the Court. On September 7, 1993, the Court entered a decision in SAB Foam Recycling Associates 1982 v. Commissioner, docket No. 5103- 92. This decision reflected a full concession by SAB Foam of all items of income (loss) and credit previously claimed for the partnership. E. Petitioners’ Introduction to Plastics Recycling In 1981 and 1982, petitioner, Lewin, and Feinberg were partners in LFC. In 1981 Becker offered petitioner a limited partnership share in SAB Resource Recycling Associates (SAB Resource), a limited partnership structured substantially like SAB Foam. After discussing the investment with Lewin and Feinberg, petitioners decided to purchase a quarter unit in SAB Resource for $12,500. Petitioners had no experience with the plastics materials or the plastics recycling industry. On January 14, 1982, petitioner received a letter from SAB Management, as general partner of SAB Resource, signed by Becker, stating that the transaction contemplated by SAB Resource was complete and distributing a modest initial royalty. On June 7, 1982, SAB Management sent a memo to the limited partners, including petitioners, purporting to update the status of their investment in SAB Resource.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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