- 40 -                                         
          Government knew he would be filing for bankruptcy.  However,                
          during his deposition on October 17, 1996, in the case of                   
          Thompson v. United States, 95-C-1112-B (N.D. Okla.), Winer                  
          testified that the Government did not link the outcome of his               
          personal tax case to any of the Plastics Recycling partnership              
          cases.                                                                      
          K.  The Davenport Partnership Litigation                                    
               Both Winer and Davenport were represented during the                   
          Davenport TEFRA partnership litigation by Gordon at all times               
          relevant hereto, and by Hack until her withdrawal in April 1991.            
          Respondent was represented during the Davenport partnership                 
          litigation in this case by District Counsel Attorneys Mary P.               
          Hamilton, Paul V. Colleran, and Kirk S. Chaberski and by                    
          Assistant District Counsel William T. Hayes.                                
               After the issuance of the FPAA's in the Hamilton case, Winer           
          wrote a memorandum to the partners of Hamilton, Davenport and               
          Dickinson Recycling Associates, including Karras, on May 30,                
          1989.  In his memorandum, Winer enclosed a copy of a Notice of              
          Filing of Petition for Hamilton Recycling Associates and stated:            
               Please be advised that we will do the same for                         
               Dickinson, Davenport, and any other partnerships that                  
               require this filing.  We sincerely hope that you will                  
               continue to support our Legal Defense Fund so that we                  
               may continue to retain counsel to represent the                        
               partnership in order to obtain a favorable disposition                 
               of this matter.                                                        
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