Philippe and Nadine Grelsamer - Page 45

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          precisely what I had done to investigate or analyze the                     
          transaction.  I didn't just say I did due diligence, and leave it           
          open for them to define what I might or might not have done."               
               The purported value of the Sentinel EPE recycler generated             
          the deductions and credits in these cases, and that circumstance            
          was reflected in the offering memoranda.  Certainly Becker                  
          recognized the nature of the tax benefits and, given their                  
          education and professional experience, petitioners should have              
          recognized it as well.  Yet neither petitioners nor Becker                  
          verified the purported value of the Sentinel EPE recycler.                  
          Becker confirmed at trial that he relied on PI for the value of             
          the Sentinel EPE recyclers.                                                 
               Investors as technologically and financially sophisticated             
          as petitioners either learned or should have learned the source             
          and shortcomings of Becker's valuation information when he                  
          "precisely" disclosed "what [he] had done to investigate or                 
          analyze the transaction."  Grelsamer knew that Becker was not               
          qualified to perform an on-site evaluation of the recycler and              
          Morgan knew from experience "what specialized equipment or                  
          machinery costs".  Accordingly, we find that petitioners did not            
          reasonably or in good faith rely on Becker as an expert or a                
          qualified professional working in the area of his expertise to              
          establish the fair market value of the Sentinel EPE recycler and            
          economic viability of the Partnership transactions.  Becker never           






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