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Sann learned of the Plastics Recycling transactions and the
Partnerships from Maxfield, who at the time was of counsel at
Sann & Howe. The two had been introduced earlier in the year by
a mutual friend, and Maxfield had been hired to provide general
tax expertise to the firm. Maxfield told Sann that he had heard
about the Plastics Recycling transactions from Taggart. Sann had
met Taggart a year or so earlier and knew of him as a tax lawyer.
Maxfield provided Sann with a copy of an offering memorandum and
he reviewed it. By Sann's account, he spent 60 to 70 hours over
a 7- to 10-day period studying the offering memorandum.
Sann discussed the transactions with other members of Sann &
Howe, including Maxfield, at informal and formal meetings. He
queried Taggart, by phone, about his impression of PI and the
machines, and Sann testified that Taggart had responded in a
positive way. Sann did not know that Taggart was making an
investment in the Plastics Recycling transactions. He understood
that Wible was impressed with what he had seen on his visit to
PI. Sann also spoke to his contacts in the oil business, and he
asserts that from them he understood that the consensus was that
the price of oil would gradually continue to rise, though at a
lower rate than in the past. However, Sann did not consider such
speculation to be an ironclad assurance of the direction of the
price of oil.
Sann did not investigate PI or any of the entities involved
in the Plastics Recycling transactions. He recalled that Roberts
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