Philippe and Nadine Grelsamer - Page 38

                                       - 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  Next

Last modified: May 25, 2011