Stuart A. and Harriet J. Gollin, et al. - Page 81

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          liable for the negligence additions to tax, petitioners'                    
          purported reliance on the offering materials and their advisers             
          was not reasonable.                                                         
               The offering materials for the Partnerships contained                  
          numerous warnings and caveats, including the likelihood that the            
          value placed on the recyclers would be challenged by the IRS as             
          being in excess of fair market value.  At trial, Fishbach was               
          unsure if he had read the offering memoranda and speculated that            
          he spent just a short amount of time perusing them and that he              
          flipped through the risk factors.  Neither Fishbach nor Gollin              
          sought to resolve the numerous issues raised in the offering                
          memoranda.                                                                  
               Becker possessed no special qualifications or professional             
          skills in the recycling or plastics industries and petitioners              
          had no reason to believe otherwise.  Although Fishbach claims               
          that he did not know whether Hertan had any education or                    
          experience in plastics recycling, nothing in Hertan's background            
          would indicate such qualifications, and Fishbach conceded that              
          Hertan never said he had such education or experience.  Despite             
          these obvious limitations, Becker, Hertan, and petitioners never            
          hired or consulted any plastics engineering or technical experts            
          with respect to the Plastics Recycling transactions.  Becker                



          18(...continued)                                                            
          reports prepared by Carmagnola to be unreliable and of no                   
          consequence.                                                                



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