Allan J. and Brenda Becker - Page 18

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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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