Stuart A. and Harriet J. Gollin, et al. - Page 47

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               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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