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investment venture, and the offering materials reviewed by the
taxpayers did not reflect that the principals in the venture
lacked experience in the pertinent line of business. In the
Reile case, the taxpayers, a married couple, had only one year of
college between them and characterized themselves as financial
"dummies." In contrast to those cases, petitioners herein are
well educated and experienced professionals. Becker and Steele
were not independent of the SAB Recycling Partnerships and Becker
disclosed the limitations of his investigation. Cohen was not a
long-term adviser to Fredericks, and there is no evidence that he
had any expertise with respect to the Plastics Recycling
transaction. Porter did not advise Fredericks specifically with
respect to the Sentinel EPE recycler or the Plastics Recycling
transactions. In addition, the offering memoranda warned that
the Partnerships had no prior operating history and that the
general partner had no prior experience in marketing recycling or
similar equipment. Accordingly, petitioners' reliance on the
Reile and Davis cases is misplaced.
In Mollen v. United States, supra, the taxpayer was a
medical doctor who specialized in diabetes and who, on behalf of
the Arizona Medical Association, led a continuing medical
education (CME) accreditation program for local hospitals. The
underlying tax matter involved the taxpayer's investment in
Diabetics CME Group, Ltd., a limited partnership that invested in
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