Leon M. and Mary K. Jaroff - Page 15

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          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.                                                  
               After the 1981 SAB Recycling Partnerships closed, Becker had           
          an accountant sent to PI to confirm, by serial number, that as of           
          December 31, 1981, the equipment that was leased to the 1981 SAB            
          Recycling Partnerships was indeed available for use.  Becker                
          arranged for this verification, independent of PI, because he               
          understood that the investment tax and business energy credits              
          would not be available if the qualifying property was not                   
          available for use.                                                          
               Leicht also familiarized himself 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 the               
          value of the recyclers other than what was presented in the                 
          offering memoranda.  He has no education or expertise in plastics           
          materials or plastics recycling.                                            




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