- 47 -- 47 -
Gollin was a partner in an accounting firm and had nearly 20
years' experience as a forensic accountant investigating
"potential scams and the like." Fishbach was a named partner in
a law firm in which he had been practicing for nearly 20 years,
and through which he had made a number of investments locally and
nationally. Fredericks was the president and chief operating
officer of a successful advertising agency and a board member of
a plastics molding company that was recycling plastic scrap.
Certainly petitioners possessed the resources and acumen properly
to investigate the Partnership transactions. We hold that
petitioners did not reasonably or in good faith rely on Becker as
an expert or a qualified professional working in the area of his
expertise to establish the fair market value of the Sentinel EPE
recycler and economic viability of the Partnership transactions.
Becker never assumed such responsibility, and he fully described
the particulars of his investigation, taking care not to
mischaracterize it as "due diligence."
In the end, Becker and petitioners relied on PI personnel
for the value of the Sentinel EPE recyclers and the economic
viability of the Partnership transactions. See Vojticek v.
Commissioner, T.C. Memo. 1995-444, to the effect that advice from
such persons "is better classified as sales promotion." Becker
did not have any education, special qualifications, or
professional skills in plastics materials or plastics recycling.
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