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the Sentinel EPE recycler. Canno never saw a Sentinel EPE
recycler and never prepared any kind of formal, written analysis
of the venture. The facts of these cases are distinctly
different from those in the Mollen case. Therefore, we consider
petitioners' arguments with respect to the Mollen case
inapplicable here.
5. Conclusion as to Negligence
Under the circumstances of these cases, these highly
sophisticated petitioners failed to exercise due care in claiming
large deductions and tax credits with respect to the Partnerships
on their respective Federal income tax returns. Petitioners did
not reasonably rely upon the offering materials. Becker
disclosed the extent, nature, and limitations of his
investigation of the transaction. He did not possess any
education, special qualifications, or professional skills in the
plastics or recycling industries. Nor did Miller, an insider to
the Plastics Recycling transactions upon whom petitioners and
Becker allegedly relied for the value of the recycler and the
economic viability of the transactions. See Goldman v.
Commissioner, 39 F.3d at 408; Marine v. Commissioner, 92 T.C. 958
(1989); McCrary v. Commissioner, 92 T.C. 827 (1989); Rybak v.
Commissioner, 91 T.C. 524 (1988). For these reasons and others
discussed above, we conclude that petitioners were negligent in
claiming the deductions and credits with respect to the
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