- 38 -
they discussed. Grelsamer claimed that he remembered only that
they did not discuss SAB Reclamation's tax benefits. Morgan
discussed Plymouth with Green for no more than 5 or 10 minutes.
Grelsamer testified that he discussed the tax benefits with
Israelite, his tax return preparer, but he could not remember for
how long, and Morgan testified only that he sent the offering
memorandum to Braver, his accountant in Boston. Nothing in the
records of these cases indicates what, if anything, Green,
Israelite, or Braver did to investigate the Plastics Recycling
transactions, or whether they were qualified to do so, nor is
there any record of the substance of their advice. See Bresler
v. Commissioner, supra, Pollack v. Commissioner, supra, and
Wichita Terminal Elevator Co. v. Commissioner, supra.
Petitioners have failed to show that they reasonably relied upon
Green and their tax return preparers.
c. Becker
Becker had no education, special qualifications, or
professional skills in plastics engineering, plastics recycling,
or plastics materials. In evaluating the Plastics Recycling
transactions and organizing the SAB Recycling Partnerships,
Becker supposedly relied upon: (1) The offering materials; (2) a
tour of the PI facility in Hyannis; (3) discussions with insiders
to the transactions; (4) Canno; and (5) his investigation of the
Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 NextLast modified: May 25, 2011