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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." Becker testified: "I provided every piece of
information I had available to me to Mr. Snyder and Mr. Busch."
The purported value of the Sentinel EPE recycler generated
the deductions and credits in these cases, and that circumstance
was clearly reflected in the offering memoranda. Certainly
Becker recognized the nature of the tax benefits and, given their
education and business experience, petitioners should have
recognized it as well. Yet neither petitioners nor Becker
verified the purported value of the Sentinel EPE recycler.
Becker confirmed at trial that he relied on PI for the value of
the Sentinel EPE recyclers.
At the meeting held in Snyder's office, Becker answered
petitioners' questions and described his investigation. Snyder
testified that he and Busch "took [Becker] through the same drill
we would have if it was a Simon & Schuster acquisition." Snyder
explained that from his questioning of Becker "I had to find out
if there was a market, is the market sustainable, was this
machine viable, was it technologically vulnerable, was the market
price satisfactory to sustaining the financial projections".
(Emphasis added.) Plainly, if Snyder and Busch truly had pursued
these questions vigorously, as talented and experienced
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