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fractional interests in four oil wells in Alberta, Canada.
Petitioner also invested as a limited partner in five other
unincorporated entities from 1983 to 1988. Three of these were
real estate ventures, one involved oil wells and the last
involved equipment leasing. Over the course of his career
petitioner has examined a large number of private placement
offering memoranda and has participated in the preparation of
such memoranda.
In 1981, petitioner learned of the Northeast transaction
from Raymond Grant (Grant). Petitioner first became acquainted
with Grant about 1946 when they both worked for David Berdon &
Co. in New York City. After about 2 years, Grant left David
Berdon & Co. to enter the mutual fund business. Grant became
general counsel and senior vice president at Waddell & Reed, a
large mutual fund organization in Kansas City. He returned to
New York in the mid-1970's. At that time Grant became a member
of the same tennis and social club as petitioner. During 1981
Grant was an investment banker, an attorney, and an accountant.
He was also the president and 100 percent owner of the stock of
ECI.
After learning of the Northeast transaction from Grant,
petitioner spoke with Richard Roberts (Roberts), a businessman
and the general partner in Northeast. Roberts was a 9-percent
shareholder in F & G and the general partner in a number of
limited partnerships which leased Sentinel EPE recyclers. Grant
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