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petitioners were not ignorant of his limitations. According to
Grelsamer, the fact that Becker was not an engineer severely
handicapped his ability to evaluate the recyclers when he visited
PI. Grelsamer did not even think that the PI personnel could
"talk to him [Becker]." Despite these obvious limitations,
Becker and petitioners never hired or consulted any plastics
engineering or technical experts with respect to the Plastics
Recycling transactions. Becker spoke with his client, Canno, who
apparently had some knowledge of the plastics industry, but the
substance of Canno's purported comments is doubtful and he had
only minimal information about the transaction. At trial, Becker
confirmed that in the end he relied exclusively on PI, its
personnel, and the offering materials as to the value and
purported uniqueness of the machines. With respect to Green and
petitioners' tax return preparers, the records in these cases are
wholly inadequate as to their purported qualifications,
investigations, if any, and advice regarding the Plastics
Recycling transactions.
In support of their contention that they acted reasonably,
petitioners cite Mauerman v. Commissioner, 22 F.3d 1001 (10th
Cir. 1994), revg. T.C. Memo. 1993-23. However, the facts in the
Mauerman case are distinctly different from the facts of these
cases. In Mauerman, the Tenth Circuit Court of Appeals held that
the Commissioner had abused her discretion by not waiving a
section 6661 addition to tax. Like section 6659, a section 6661
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