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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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