Stuart A. and Harriet J. Gollin, et al. - Page 46

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          analysis of the Plastics Recycling transactions reflected this              
          circumstance.  Gollin knew that Becker was not an engineer or               
          expert in plastics materials or plastics recycling, and Fishbach            
          and Fredericks had no reason to believe otherwise.  Becker                  
          testified that he was very careful not to mislead any of his                
          clients regarding the particulars of his investigation.  As he              
          put it: "I don't recall saying to a client I did due diligence *            
          * * [Rather,] I told [my clients] precisely what I had done to              
          investigate or analyze the transaction.  I didn't just say I did            
          due diligence, and leave it open for them to define what I might            
          or might not have done."                                                    
               The purported value of the Sentinel EPE recycler generated             
          the deductions and credits in these cases, and that circumstance            
          was reflected in the offering memoranda.  Certainly Becker                  
          recognized the nature of the tax benefits and, given their                  
          education and professional experience, petitioners should have              
          recognized it as well.  Yet neither petitioners nor Becker                  
          verified the purported value of the Sentinel EPE recycler.                  
          Petitioners ultimately relied on Becker, and Becker confirmed at            
          trial that he relied on PI for the value of the Sentinel EPE                
          recyclers.  Investors as sophisticated as petitioners either                
          learned or should have learned the source and shortcomings of               
          Becker's valuation information when he "precisely" disclosed                
          "what [he] had done to investigate or analyze the transaction."             






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