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from the SAB Recycling Partnerships for preparing their
partnership returns. As Becker himself testified, potential
investors could not have read the offering materials and been
ignorant of the financial benefits accruing to him.
Becker testified that he and petitioner discussed the
propriety of the tax benefits, Becker's visit to PI, and Canno's
comments. Becker did not guarantee the tax benefits to
petitioner. As he recalled, "I explained to * * * [petitioner],
as I had explained to virtually all the people I had spoken to,
that the only benefit he could count on * * * was a write-off of
the investment in the event the deal failed." Becker thought it
was an appropriate investment for petitioner because, "It had
minimal risk on an after-tax basis, after-tax meaning a write-off
of the investment, not any of the other tax attributes that were
attributed to it". Becker testified that he was very careful not
to mislead any of his clients regarding the particulars of his
investigation. As he put it: "I don't recall saying to a client
I did due diligence * * *. [Rather,] I told * * * [my clients]
precisely what I had done to investigate or analyze the
transaction. I didn't just say I did due diligence, and leave it
open for them to define what I might or might not have done."
The record in this case shows that petitioner made no effort
to learn about the Sentinel EPE recyclers, the Partnerships, or
the Plastics Recycling transactions in general. He ignored
Becker's instruction to read the offering memoranda, was unaware
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