- 9 -
buying, leasing, and licensing the same Sentinel EPS Recyclers
and/or other recycling equipment. With respect to this potential
conflict of interest, the offering memorandum provides:
The existence of such other limited partnerships may
create conflicts and result in actions taken by, or
omitted to be taken by, (Mr. Roberts) which may be
adverse to the interest of the Limited Partners.
Furthermore, PI, ECI, F&G, RRI, some of the shareholders
of F&G, ECI, and RRI, are, and may again become, engaged
in the business of buying, selling, leasing, licensing
the use of and/or operating recycling equipment,
including other Sentinel EPS Recyclers and other
recycling equipment similar in design and function, or
rendering consulting services with respect thereto.
Before he invested in Madison, Mr. Greer expected that
Madison was going to provide a tax savings of approximately $1.75
for each dollar invested. The offering memorandum sets forth the
1982 tax benefits/savings of an investment in Madison as follows:
Projected Regular Projected Tax Payment
Investment Energy Tax Credits Deductions
$50,000 $77,000 $38,610
Included as part of the offering memorandum package was the
legal opinion, an undated “form of opinion” letter (form of
opinion), which was based on facts supplied by Madison’s general
partner. The form of opinion stated: “This letter is intended
for your [the general partner’s] own individual guidance and for
the purpose of assisting prospective purchasers and their tax
advisors in making their own analysis, and no prospective
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: November 10, 2007