- 38 -                                         
          opinion 72 F.3d 123 (3d Cir. 1995); Sacks v. Commissioner, supra;           
          Steerman v. Commissioner, T.C. Memo. 1993-447; Rogers v.                    
          Commissioner, T.C. Memo. 1990-619; see also the Plastics                    
          Recycling cases cited supra note 8.                                         
               In addition to his professional experience as a corporate              
          and Federal securities lawyer, by 1981 Friedman had made a "great           
          number" of personal investments.  His approach to these                     
          investments was rigorous and methodical:  he read the prospectus            
          or private offering memorandum, spoke to an expert in the                   
          pertinent industry, investigated the risk factors described in              
          the offering materials, consulted industry reports, and spoke to            
          other active investors or lawyers.  With respect to Clearwater,             
          however, Friedman's investigation was wanting.  Friedman did not            
          speak to a plastics materials or plastics recycling expert, or              
          investigate the risk factors described in the offering                      
          memorandum, or consult plastics industry trade journals or                  
          reports.  His investigation of Clearwater entailed nothing more             
          than reading the offering memorandum and discussing the                     
          investment with other attorneys at Shea & Gould.  Friedman                  
          testified that he also provided a copy of the offering memorandum           
          to his accountant and that his accountant did not advise against            
          the investment.  The accountant, however, had no experience in              
          plastics or plastics recycling, and did not independently                   
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