- 41 -- 41 -
aspects of the contemplated venture. David v. Commissioner,
supra, Goldman v. Commissioner, supra; Freytag v. Commissioner,
supra; Beck v. Commissioner, 85 T.C. 557 (1985); Lax v.
Commissioner, T.C. Memo. 1994-329, affd. without published
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.
b. Becker
Becker had no education, special qualifications, or
professional skills in plastics engineering, plastics recycling,
or plastics materials. In evaluating the Plastics Recycling
transactions and organizing the SAB Recycling Partnerships,
Becker supposedly relied upon: (1) The offering materials; (2) a
tour of the PI facility in Hyannis; (3) discussions with insiders
to the transactions; (4) Canno; and (5) his investigation of the
reputation and background of PI and persons involved in the
transactions.
Despite his lack of knowledge regarding the product, the
target market, and the technical aspects at the heart of the
Plastics Recycling transactions, Becker did not hire an expert in
plastics materials or plastics recycling, or recommend that his
clients do so. The only independent person having any connection
with the plastics industry with whom Becker spoke was Canno. A
client of Becker Co., Canno was a part owner and the production
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