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recycler. Indeed, PI's Hyannis plant was not far from SBA's
biggest supplier, and Becker could have told petitioner where to
find plastics industry trade journals. Moreover, petitioner did
not even read the offering materials provided to him by Becker--
despite express advice that he should do so. Petitioner's
disregard of the offering materials undermines any contention
that he monitored his investments. Accordingly, petitioner's
reliance on the Heasley, Reile, and Davis cases is misplaced.
See Prohaska v. Commissioner, T.C. Memo. 1991-306; Prohaska v.
Commissioner, T.C. Memo. 1991-305.
The facts of petitioner's case also distinguish it from
Steinberg v. Commissioner, a Plastics Recycling case consolidated
for opinion with Zidanich v. Commissioner, T.C. Memo. 1995-382,
wherein this Court declined to impose the negligence additions to
tax. In the Steinberg case, the taxpayers were husband and wife.
Neither had any financial or investment background. The taxpayer
wife, who was not employed outside the home, had relied upon her
father in all financial matters. He had advised her that after
his death she should rely upon her brother, a highly successful
investor. Accordingly, on her father's death, Mrs. Steinberg
turned over management of her inherited funds to her brother,
Morton Efron (Efron). Efron invested Mrs. Steinberg's
inheritance in a limited partnership, AMBI, which was formed as
an investment vehicle for Efron himself, his sister (Mrs.
Steinberg), and their spouses. AMBI invested in a number of
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