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benefits; however, the substance of these conversations is not
disclosed in the record. Taggart and other members of the law
firm of Windels, Marx, Davies and Ives prepared the offering
memorandum, tax opinion, and other legal documents for the
initial Plastics Recycling partnership, Clearwater, and 16 other
Plastics Recycling partnerships, including Sunbelt. Taggart was
the head of the tax department of Windels, Marx, Davies and Ives
and taught tax law as an adjunct professor at New York University
(NYU) Law School. Taggart had previously been employed by the
U.S. Treasury Department and as a full-time faculty member of NYU
Law School. Taggart owned a 6.66-percent interest in a second-
tier Plastics Recycling partnership. Miller was a practicing
attorney who specialized in tax matters. Miller was employed as
corporate counsel to PI for 29 years and at all times relevant to
this case. Storey tentatively decided to invest in Sunbelt for
various reasons, including its "attractive" tax benefits.
In December 1981, Storey went to Hyannis, Massachusetts, to
visit PI's facilities. While in Hyannis, Storey spent 7 hours at
PI where he toured PI's facilities and observed a demonstration
of a recycler. While at PI's facilities, Storey observed the
presence of security officers and the use of personnel name tags.
During this visit, Storey met John D. Bambara (Bambara) and
Anthony Giovannone (Giovannone). Bambara is the president of PI
and member of its board of directors. Bambara is also the
president, treasurer, clerk, and director of FMEC Corp., as well
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