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Plastics Recycling transaction. Becker Co. prepared petitioner's
1981 and 1982 returns and petitioner reviewed them. Petitioner
and Becker did not discuss the Partnership transactions in
conjunction with the preparation of either return. Petitioner
understood that his brother's (Becker) background was tax
oriented.
Petitioner has no education or work experience in plastics
recycling or plastics materials. He never read the SAB Recovery
and SAB Recycling offering memoranda. Petitioner did not see a
Sentinel recycler prior to investing in the Partnership
transactions or otherwise independently investigate the Sentinel
recyclers. He did not know when or in what amounts the
Partnerships were projected to realize a profit. Petitioner was
unaware that Becker, as president and sole shareholder of the
general partner of the SAB Recycling partnerships, received
substantial fees from the Partnerships. In the end, petitioner
knew that the Partnerships leased plastics recyclers, and that
his brother, the accountant, claimed the machines were state-of-
the-art. Petitioner made little, if any, effort to learn more
about the transaction, although he was an experienced businessman
and corporate officer. Petitioner never made a profit in any
year from his participation in the Partnership transactions.
OPINION
We have decided a large number of the Plastics Recycling
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