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uneducated, unsophisticated investors in 1981. Not only were
petitioners well-educated and financially successful in their
professions and businesses, but also they were accustomed to
considering tax-oriented investments, since they had made such
investments in the past.
In evaluating the Hyannis transaction, petitioners purport
to have relied on Greenstein and to some extent the offering
memorandum. With respect to petitioners Berry, they did little
beyond discussing the Hyannis transaction with Greenstein. While
on vacation near Hyannis during the summer of 1981, they visited
the plant site but did not enter it. When asked at trial whether
she had read the offering memorandum, petitioner Berry testified,
"I leafed through it," and "I don't know whether you would call
it reading it." Petitioner Berry testified that she did not have
any idea of the value of the recyclers. When asked if their
value was important to her, she replied, "I guess I didn't think
much about that." Petitioner Berry testified that she and her
husband basically relied on Greenstein.
As for petitioners Pace, Anthony Pace was familiar with
offering memoranda from his work at Bear Stearns & Co. He stated
that he "relied on the offering memorandum" in evaluating
Hyannis, yet when asked at trial how much time he spent reviewing
it, he too replied, "I leafed through it." Petitioner Pace
testified that his first impression of Hyannis was "it sounds
awfully good, sounds too good in a sense." Nonetheless, all that
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