Bruce and Lois Zenkel, et al. - Page 16

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          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 any of the 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.  In addition,               
          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 particularly sought to protect               
          himself against liability.                                                  
               Leicht and Tucker also familiarized themselves 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             




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