- 16 - 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. Petitioners’ Introduction to Plastics Recycling In 1981 and 1982, petitioner, Cohen, and Feinberg were partners in LFC. In 1981, Feinberg approached petitioner about SAB Resource Recycling Associates (SAB Resource), a limited partnership structured substantially like SAB Foam. Petitioner explained to Feinberg his alleged familiarity with PI and suggested Miller as a resource for more information. He then talked with Miller about the transaction. Miller reminded petitioner of his experience with PI but never specifically discussed the value of the machines with petitioner. Instead, Miller stated to petitioner that valuations were done on the recyclers and that as to the people who did the valuations, “he knew them, they were qualified, they appeared to be qualified”. Petitioner next sought the advice of his friend Dooskin.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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