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(the Gollin and Fishbach cases). His testimony has been
disregarded with respect to docket No. 21847-90 (the Fredericks
case). Tucker did not testify in any of the trials.
During his investigation of the Plastics Recycling
transactions, Becker did not hire any plastics, engineering, or
technical experts, or recommend that his clients do so. Becker
discussed the transactions with Michael Canno (Canno) of the
Equitable Bag Co., a manufacturer of paper and plastic bags.
Canno never saw the recyclers or the pellets and never wrote any
reports assessing the equipment or the pellets. In addition,
Becker retained a law firm, Rabin & Silverman, to assist him in
organizing the SAB Recycling Partnerships. See Spears v.
Commissioner, T.C. Memo. 1996-341, to the effect that in
employing the law firm, Becker sought particularly to protect
himself against liability.
Leicht and Tucker also familiarized themselves with the
Plastics Recycling transactions. Leicht has a B.A. degree in
finance and accounting from Penn State University, a J.D. from
SUNY Buffalo, and an LL.M. in taxation from New York University
School of Law. Leicht ran a mathematical check on the numbers
contained in the offering materials for Becker, but he did not
test the underlying assumptions upon which they were based. He
also visited PI in Hyannis and met with Miller and other insiders
to the transactions. Leicht never communicated an opinion as to
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