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much to him and I'm sure it didn't. They can't talk to him."
Grelsamer purportedly concluded that the Sentinel EPE recycler
was unique on the basis of his discussions with Becker and the
assessments by Ulanoff and Burstein, whose credentials he
believed that Becker had checked.
Grelsamer has no education in plastics recycling or plastics
materials. He knew that Becker was the de facto general partner
of SAB Reclamation and that Becker had no experience in plastics
recycling. Grelsamer did not know whether Green had any
experience in the plastics recycling business. Grelsamer did not
investigate the value of the Sentinel EPE recycler or how it
functioned or compare it with other similar products. He did not
visit any of the end-user locations or review any periodicals
relating to resin prices. Grelsamer did not talk to Green about
the tax benefits associated with SAB Reclamation. Instead he
discussed them with his tax return preparer, Abraham Israelite.
Six months after investing in SAB Reclamation, Grelsamer invested
in a second plastics recycling partnership. Grelsamer never made
a profit in any year from his interest in SAB Reclamation.
2. David E. Morgan
Morgan resided in Palm Beach, Florida, at the time his
petition was filed. He was born and raised in Poland. When he
was 8 or 9 years old, oil was discovered on his family's farm,
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