- 16 - On December 9, 1991, respondent issued a notice of final partnership administrative adjustment (FPAA) to SAB Management for 1982. In the FPAA, respondent disallowed all items of income, losses, deductions, and credits reported with respect to SAB Foam’s equipment leasing activities for 1982. Accordingly, respondent: (1) Increased ordinary income by $662,556; (2) determined that SAB Foam’s investment and business energy tax credits with respect to the recycling equipment were zero, instead of the $7 million claimed as the qualified investment on 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. Petitioner’s Introduction to Plastics Recycling In 1981 and 1982, petitioner, Cohen, and Lewin were partners in LFC. In 1981 Becker retained petitioner to advise him for his own protection relating to SAB Resource, a limited partnership structured substantially like SAB Foam. Petitioner received the offering materials for SAB Resource and, according to his testimony, performed a “very, very careful and detailed study ofPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011