Malcolm I. Lewin and Trina Lewin - Page 16

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          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                
          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.               

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