- 67 -
therefore, that respondent should have waived the section 6659
additions to tax.15 However, as we explained above in finding
petitioners liable for the negligence additions to tax,
petitioners' purported reliance on the offering materials and
Tucker was not reasonable.
Petitioners did not carefully read the offering memoranda.
To the extent that they reviewed either of them, they did not
give due consideration to the numerous warnings and caveats
contained therein. We found petitioner's recollection of events
to be unreliable and his testimony suspect. Becker possessed no
special qualifications or professional skills in the recycling or
plastics industries, and the record indicates the same was true
of Tucker. Despite these obvious limitations, Tucker, Becker,
and petitioners never hired or consulted any plastics engineering
or technical experts with respect to the Plastics Recycling
transactions. Becker spoke with 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 anyway. At trial, Becker
confirmed that in the end he relied exclusively on PI, its
personnel, and the offering materials as to the value and
15 In their posttrial brief, petitioners referenced the reports
prepared by Carmagnola in support of the reasonableness of the
claimed valuation. For reasons discussed supra, we consider the
reports prepared by Carmagnola to be unreliable and of no
consequence.
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