Stuart A. and Harriet J. Gollin, et al. - Page 41

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          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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