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the Whitman transactions.
Elliot I. Miller (Miller), a practicing attorney who was
experienced in tax matters, was the corporate counsel to PI.
Miller represented Grant personally and Grant’s clients who
invested in programs that Grant promoted. Miller met Grant in
the 1970's when Grant was involved in marketing a coal mine.
Miller was also a 9.1-percent owner of F&G.
John Y. Taggert (Taggert) was a well-known tax attorney, the
head of the tax department of the New York law firm of Windells,
Marx, Davis & Ives, and an adjunct professor of tax law at the
New York University Law School. Taggert had been acquainted with
Miller for many years before 1982. Miller recommended that
Roberts employ Taggert and his firm as counsel to the general
partner in the initial Plastics Recycling partnership. Taggert
and other members of his firm prepared the offering memorandum,
tax opinion, and other legal documents for the initial Plastics
Recycling partnership, for the Clearwater partnership, and for
about 16 other Plastics Recycling partnerships, including
Whitman. Taggert owned a 6.66-percent interest in a second-tier
Plastics Recycling partnership.
Robert Gottsegen (Gottsegen) was a businessman active in the
plastics industry and a longtime business associate of Bambara.
Gottsegen was the sole owner of RRI, the corporation that was
involved in the joint venture in the Whitman transactions, and a
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