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the Plymouth transactions, Roberts and Grant were clients of the
accounting firm H.W. Freedman & Co. (Freedman & Co.).
Harris W. Freedman (Freedman), a certified public accountant
and the named partner in Freedman & Co., was the president and
chairman of the board of F&G. Freedman was experienced with
leveraged leasing, and he owned 94 percent of a Sentinel EPE
recycler.
Freedman & Co. prepared the tax returns for ECI, F&G, and
the Partnerships, as well as for Clearwater Group. It also
provided tax services to John D. Bambara (Bambara). Bambara was
the 100-percent owner of FMEC, as well as its president,
treasurer, clerk, and director. Bambara was also the president
of PI and a member of its board of directors. He, his wife, and
his daughter also owned directly or indirectly 100 percent of the
stock of PI.
Anthony Giovannone (Giovannone) was the executive vice
president of PI and a member of its board of directors.
Elliot I. Miller (Miller) was the corporate counsel to PI.
In 1981, Miller was also a shareholder of F&G.
John Y. Taggert (Taggert) was a well-known tax attorney and
an adjunct professor at the New York University Law School.
Taggert was acquainted with Miller for about 15 years prior to
1981. Miller recommended that Roberts employ Taggert and his
firm as counsel. Taggert and other members of his firm prepared
private offering memoranda, tax opinions, and other legal
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