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professional money manager. Beginning in the early 1970's,
petitioners combined their talents and together they began
organizing and syndicating oil drilling ventures. Morgan
estimated that they drilled about 10 to 15 wells a year in the
mid to late 1970's. Because of their investment acumen and
thorough, cautious approach, petitioners' oil drilling ventures
yielded a 90- to 95-percent success rate. Certainly petitioners
possessed the engineering and financial intellect, skills,
experience, and resources to investigate properly the viability
of the Plastics Recycling transactions either themselves or by
employing an independent, qualified expert.
Petitioners claim that they relied on Becker for the bona
fides and viability of the Partnership transactions. Yet
Becker's expertise was in taxation, not plastics materials or
plastics recycling, and his investigation and analysis of the
Plastics Recycling transactions reflected this circumstance.
Petitioners knew that Becker was not an engineer or expert in
plastics materials or plastics recycling. Grelsamer even
testified that because Becker was not an engineer his visit to PI
could not have meant much to him and that Grelsamer was sure that
it did not. Moreover, Becker testified that he was very careful
not to mislead any of his clients regarding the particulars of
his investigation. As he put it: "I don't recall saying to a
client I did due diligence * * * [Rather,] I told [my clients]
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