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was dependent on internal recycling. The nature of the recycle
stream was relevant to the economics of the project. The
recycling process oxidized ethylbenzene and propylene to produce
propylene oxide as the main product, and dehydrogenated
methybenzyl alcohol to produce styrene, the monomer of
polystyrene, as a secondary product. SDC performed most of the
technical work for the Opstrand venture, and Arco was responsible
for the financing.
Petitioner’s Investment History
Before 1980, petitioner’s investment portfolio consisted of
stocks and bonds. In 1980, petitioner became a client of Marcus
V. Cole (Mr. Cole), a financial adviser for Merrill Lynch. In
1980, petitioner also purchased rental property on Hilton Head
Island.
Petitioner’s income increased significantly from 1980 to
1981 because of a $1 million bonus. After he received the $1
million bonus, petitioner diversified his investments. During
1981, petitioner invested in several limited partnerships,
including at least three oil and gas partnerships. Petitioner
received documents related to the oil and gas investments, but he
did not have anyone else review them. During 1981, petitioner
also invested in a bus rental activity. Petitioner incurred
losses as a result of the oil and gas investments and the bus and
property rental activities.
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