Peter and Ursula Reimann, et al. - Page 8

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          Specifically, the offering memoranda state:  (1) That there is a            
          substantial likelihood of audit by the Internal Revenue Service             
          (IRS) and that the purchase price paid by F & G Corp. to ECI                
          Corp. probably would be challenged as being in excess of fair               
          market value; (2) that the Partnerships have no prior operating             
          history; (3) that the general partners have no prior experience             
          in marketing recycling or similar equipment; (4) that the limited           
          partners have no control over the conduct of the Partnerships'              
          business; (5) that there is no established market for the                   
          Sentinel EPE recyclers; (6) that there are no assurances that               
          market prices for virgin resin will remain at their current costs           
          per pound or that the recycled pellets will be as marketable as             
          virgin pellets; and (7) that certain potential conflicts of                 
          interest exist.                                                             
               Petitioners in the cases under consideration do not have any           
          education or work experience in plastics recycling or plastic               
          materials.  They did not independently investigate the Sentinel             
          EPE recyclers or see a Sentinel EPE recycler or any other type of           
          plastics recycler prior to participating in the recycling                   
          ventures.                                                                   
               Petitioners each learned of their respective Partnership               
          transaction from members of the accounting firm Bachmann,                   
          Schwartz, and Abramson (Bachmann, Schwartz).  Bachmann, Schwartz            
          was formed in 1972 by Donald Bachmann (Bachmann) (deceased prior            
          to trial), a certified public accountant (C.P.A.), William                  
          Abramson (Abramson), also a C.P.A., Richard Schwartz and Ivan               



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