Peter and Ursula Reimann, et al. - Page 16

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          benefits exceeded the amount he invested, and that they were                
          generated by the purported value of the Sentinel EPE recyclers.             
          He read the warnings in the offering memorandum that the IRS                
          would likely audit Plymouth and challenge the value of the                  
          machines.  Brodie did nothing to verify the purported value of              
          the Sentinel EPE recycler and undertook no research into Plymouth           
          or plastics recycling aside from reviewing the offering                     
          memorandum and speaking with Greene.  Although Brodie spoke to              
          Greene about the investment every few months, he never knew for             
          sure whether the recyclers were ever delivered to end-users.  In            
          fact, the recyclers were eventually placed with end-users which             
          did not have sufficient amounts of recyclable plastic scrap                 
          material ever to pay off the notes on the recyclers.  Brodie                
          never made an economic profit in any year from Plymouth.  After             
          he received the tax credits in 1981, however, Brodie was not                
          concerned that he received no dividends or return of capital with           
          respect to the Plymouth investment.                                         
          3.  Marvin and Suzanne Yarnell, Docket No. 3398-92, and Philip              
          and Roberta Yarnell, Docket No. 13892-92                                    
               Petitioners Marvin and Suzanne Yarnell resided in Old                  
          Westbury, New York, when their petition was filed.  Petitioners             
          Philip and Roberta Yarnell resided in Manhasset, New York, when             
          their petition was filed.                                                   
               During 1981, Marvin Yarnell was a 75-percent owner and                 
          primary operating executive of Yarnell Fabrics Corporation                  
          (Yarnell Fabrics) and Yarnell Fabrics International, Ltd. (YFIL).           



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