Robert D. and Patricia K. Kaliban, et al. - Page 19

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            involved in a plastics company.  Kaliban did not read the Poly                            
            Reclamation offering memorandum or otherwise investigate or                               
            analyze any aspect of the transactions.  He assumed that if Alter                         
            was investing in the Plastics Recycling transactions, it was a                            
            good investment.                                                                          
                  2.  Steve and Lispet Roland                                                         
                  Petitioners Steve and Lispet Roland resided in New York, New                        
            York, when their petition was filed.  After graduating from high                          
            school, Steve Roland (Roland) pursued dramatic training for 2                             
            years and then served in the Army.  Upon completing his military                          
            service, Roland performed on Broadway, in night clubs, and on                             
            radio.  His career eventually shifted to the commercial field                             
            where he engaged in on camera performances and then concentrated                          
            in voice-over work.  Roland's workload and earnings grew quickly,                         
            and in 1968 he retained Alter's firm to manage his finances and                           
            plan for taxes.  Alter and Feinstein received Roland's income and                         
            paid his bills, such as his agent's commissions, maintained books                         
            tracking Roland's investments and residuals, and prepared the                             
            Rolands' tax returns.  They also reviewed investments that had                            
            been suggested to Roland by others.  Roland incorporated his                              
            professional services under the name Steve Roland, Inc. (SRI) in                          
            1968.  SRI, whose only asset was its arrangement for the services                         
            of Roland, filed a separate return from him.  Prior to 1981,                              
            Roland invested in a profitable commercial real estate venture in                         
            which Alter also invested.  On their joint 1981 Federal Income                            




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