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of when and how the Partnerships were supposed to turn a profit,
and failed to read the available explanation that Becker received
substantial fees from the Partnerships. In addition,
petitioner's recollection of events, and of what Becker told him,
is suspect. Becker testified that he sent petitioner a copy of
the SAB Recovery offering memorandum and "told him to look at
it", and that he also sent him a copy of the SAB Recycling
offering memorandum. Petitioner claims that he did not review
the SAB Recovery offering memorandum, and by extension the SAB
Recycling offering memorandum, because he "didn't know there was
an offering memorandum available." Petitioner claims that during
their breakfast conversation, Becker indicated that "he felt
that, shortly down the road, * * * [SAB Recovery] would start to
show a profit, and I could reap the benefits of that." Becker,
however, testified that he did not expect SAB Recovery to receive
any cash receipts in 1982. He explained that he "didn't
legitimately and appropriately expect that we would close one day
and the checks would come in." Becker "legitimately anticipated
that there would be little or no revenue in the first year of
operation of this equipment."
Asked if he invested in the Partnerships without knowing
anything about them, petitioner replied as follows:
I not--I didn't--I knew something about it. It wasn't
just giving * * * [Becker] a check. I did know that
they recycled plastics and they turned used plastic
into usable plastic. And they did have state-of-the-
art machinery, which is important to me.
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