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private placement offering memorandum, Freedman & Co. reviewed
those financial projections and made suggestions as to format and
substance.
Freedman & Co. also provided tax services to John D. Bambara
(Bambara). Bambara was the president and sole owner of First
Massachusetts Equipment Corp. (FMEC Corp.), another entity that
was involved in Provizer v. Commissioner, T.C. Memo. 1992-177.
Bambara was also the president of PI and a member of its board of
directors and with his wife and daughter owned 100 percent of the
stock of PI, the corporation that sold the recyclers to ECI in
the Dickinson 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
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