- 9 - 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 tax opinion expressly warned that the investment and energy tax credits available to limited partners would be reduced or eliminated if the partnership could not demonstrate that the price paid for the recyclers approximated their fair market value. The tax opinion did not purport to rely on any independent confirmation of the fair market value of the recyclers. Instead, the tax opinion clearly relied on Ulanoff’s conclusion that the purchase price to be paid by F&G was fair and reasonable. The tax opinion also states: “PI, ECI, F&G, and the Partnership have represented to us that the prices paid by ECI and by F&G and the terms of the Lease were negotiated at arm’s length.” The tax opinion concludes that the basis to the partnership upon which the aggregate investment and energy tax credits are to be computed is the price paid by F&G for the recyclers. C. Individuals Involved Petitioner attended New York University, School of Commerce, Accounts, and Finance on a university scholarship and graduated in 3-1/2 years. He joined the Naval Reserve while attending Harvard Law School during the Korean War and graduated from the law school in 1953. He then attended Officer’s Candidate School, received his commission, transferred to the Naval Supply Depot,Page: 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