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the Partnership transactions, a number of other limited
partnerships entered into transactions similar to the Partnership
transactions, also involving Sentinel EPE recyclers and Sentinel
expanded polystyrene (EPS) recyclers. We refer to these
collectively as the Plastics Recycling transactions.
B. The Partnerships
SAB Recovery and SAB Reclamation are New York limited
partnerships. SAB Recovery was formed in late 1981 and SAB
Reclamation was formed in early 1982. Both partnerships were
organized and promoted by Stuart Becker (Becker), a certified
public accountant (C.P.A.) and the founder and principal owner of
Stuart Becker & Co., P.C. (Becker Co.), an accounting firm that
specialized in tax matters. Becker organized a total of six
recycling partnerships (the SAB Recycling Partnerships). Two of
the SAB Recycling Partnerships closed in late 1981, two closed in
early 1982, and two more closed in late 1982.
The general partner of each of the SAB Recycling
Partnerships, including SAB Recovery and SAB Reclamation, is SAB
Management Ltd. (SAB Management). SAB Management is wholly owned
by Scanbo Management Ltd. (Scanbo), which is wholly owned by
Becker. Scanbo is an acronym for three of Becker's children:
Scott, Andy, and Bonnie. The officers and directors of SAB
Management and Scanbo are as follows: (1) Becker, president and
director; (2) Noel Tucker (Tucker), vice president, treasurer,
and director; and (3) Steven Leicht (Leicht), vice president,
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