Stuart A. and Harriet J. Gollin, et al. - Page 34

                                       - 34 -- 34 -                                        
          1990).                                                                      
               Petitioners' assertion that they reasonably expected an                
          economic profit from the Partnership transactions is not                    
          credible.  Petitioners did not seriously review the offering                
          memoranda, investigate the Plastics Recycling transactions, or              
          otherwise educate themselves in plastics recycling.  Moreover,              
          testimony by one of respondent's experts establishes that the oil           
          pricing changes during the late 1970's and early 1980's did not             
          justify petitioners' claiming excessive investment credits and              
          purported losses based on vastly exaggerated valuations of                  
          recycling machinery.                                                        
               Petitioners' failure seriously to learn about the                      
          Partnership transactions undermines their contention that they              
          reasonably expected an economic profit from them.  Gollin was an            
          experienced forensic accountant who described himself as "very              
          into investigation and potential scams and the like," yet he did            
          not ask to see SAB Reclamation's books and records, nor did he              
          see a Sentinel EPE recycler prior to investing.  Also, Gollin               
          knew there were no end-users committed to the transaction, and he           
          stipulated that he does not know whether SAB Reclamation had any            
          assets.  Fishbach was unsure if he had read the offering                    
          memoranda, but speculated that he spent just a short amount of              
          time perusing them and that he flipped through the risk factors.            
          Asked if he reviewed the financial projections, Fishbach replied,           
          "Absolutely not."  Fredericks did not understand most of the                




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