John Sann and Marianne Sann, et al. - Page 10

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          addition to the Partnership transactions, a number of other                 
          limited partnerships entered into transactions similar to the               
          Partnership transactions, also involving Sentinel EPE recyclers             
          and Sentinel expanded polystyrene (EPS) recyclers.  We refer to             
          these collectively as the Plastics Recycling transactions.                  
          B.  The Partnerships                                                        
               Empire, Plymouth, and Foam are New York limited                        
          partnerships.  Empire closed on November 23, 1981; Plymouth                 
          closed on December 21, 1981; and Foam closed on September 22,               
          1982.  Foam is subject to the provisions of the Tax Equity and              
          Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96                
          Stat. 324.                                                                  
               Richard Roberts (Roberts) is the general partner of each of            
          the Partnerships.  Roberts also was the Tax Matters Partner (TMP)           
          for Foam during 1982 and at all other times relevant hereto.                
               With respect to each of the Partnerships, a private                    
          placement memorandum was distributed to potential limited                   
          partners.  Reports by F & G Corp.'s evaluators, Dr. Stanley M.              
          Ulanoff (Ulanoff), a marketing consultant, and Dr. Samuel Z.                
          Burstein (Burstein), a mathematics professor, were appended to              
          the offering memoranda.  Ulanoff owns a 1.27-percent interest in            
          Plymouth and a 4.37-percent interest in Taylor Recycling                    
          Associates.  Burstein owns a 2.605-percent interest in Empire and           
          a 5.82-percent interest in Jefferson Recycling Associates.  Like            
          Empire and Plymouth, Taylor Recycling Associates and Jefferson              

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