John Sann and Marianne Sann, et al. - Page 14

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          Maxfield earned an undergraduate degree in 1955 from Augustana              
          College and was elected to Phi Beta Kappa.  He then attended                
          Michigan Law School where he became a member of the Law Review              
          and was elected to the Order of the Coif.  He graduated Summa Cum           
          Laude in 1958.  After law school Maxfield became employed by the            
          law firm of White & Case in New York City.  In 1963 he left White           
          & Case to be an assistant professor in the graduate tax program             
          at the New York University (NYU) Law School.  He became a full              
          professor 12 to 14 years later.  Maxfield has written articles              
          for Law Reviews and co-authored a book on Federal estate and gift           
          taxation.  During his tenure at NYU he has been "of counsel" to             
          various law firms.  For approximately 10 years he was of counsel            
          to the law firm of Gifford, Woody, Carter & Hayes.  Sometime in             
          1981 he became of counsel to the law firm of Sann & Howe.  Among            
          his various functions at the firm, Maxfield reviewed tax-                   
          advantaged investments at Sann & Howe.                                      
               Maxfield learned of the Plastics Recycling transactions in             
          1981 from John Y. Taggart (Taggart), a tax partner at the law               
          firm of Windels, Marx, Davies & Ives (WMDI).  Taggart and other             
          attorneys at WMDI prepared the offering memoranda, tax opinion,             
          and other legal documents for Empire and Plymouth.  Maxfield and            
          Taggart were close personal friends.  They had known each other             
          since 1959 when they were colleagues at White & Case.  Maxfield             
          was the "best man" at Taggart's wedding and named Taggart as                
          executor of his will.  Before joining WMDI, Taggart also had been           

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