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In organizing the SAB Recycling Partnerships, Becker was not
allowed to change the format of the transactions or the purchase,
lease, or licensing prices of the Sentinel EPE recyclers. He was
allowed only to conduct a limited investigation of the proposed
investments and choose whether or not to organize similar
partnerships. Becker relied heavily upon the offering materials
and discussions with persons involved in the matter to evaluate
the Plastics Recycling transactions. He and two other members of
Becker Co., Leicht and Tucker, investigated PI and visited its
plant in Hyannis, Massachusetts, where they saw the Sentinel EPE
recyclers. Tucker did not testify at either of petitioners'
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. Becker retained
a law firm, Rabin & Silverman, to assist him in organizing the
SAB Recycling Partnerships. See, e.g., Spears v. Commissioner,
T.C. Memo. 1996-341, to the effect that in employing the law
firm, Becker particularly sought to protect himself against
liability.
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