- 33 -
promotion;" see also Marine v. Commissioner, supra; McCrary v.
Commissioner, supra; Rybak v. Commissioner, supra; Freytag v.
Commissioner, supra; Lax v. Commissioner, supra; Steerman v.
Commissioner, supra; Rogers v. Commissioner, supra.
c. Becker
Becker possessed no education, special qualifications, or
professional skills in plastics engineering, plastics recycling,
or plastics materials. In evaluating the Plastics Recycling
transactions and organizing the SAB Recycling Partnerships,
Becker supposedly relied upon: (1) The offering materials; (2) a
tour of the PI facility in Hyannis; (3) discussions with insiders
to the transactions; (4) Canno; and (5) his investigation of the
reputation and background of PI and persons involved in the
transactions.
Despite his lack of knowledge regarding the product, the
target market, and the technical aspects at the heart of the
Plastics Recycling transactions, Becker did not hire an expert in
plastics materials or plastics recycling, or recommend that his
clients do so. The only independent person having any connection
with the plastics industry that Becker spoke to was Canno. A
client of Becker Co., Canno was a part owner and the production
manager of Equitable Bag Co., a manufacturer of paper and plastic
bags. Becker spoke to Canno about the recyclers and PI, but did
not hire or pay him for any advice. Canno did not visit the PI
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