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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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