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rely solely upon his preliminary, ill-founded valuation
estimates. The Carmagnola reports were a part of the record
considered by this Court and reviewed by the Sixth Circuit Court
of Appeals in the Provizer case, where we held the taxpayers
negligent. Consistent therewith, we find in these cases, as we
have found previously, that the reports prepared by Carmagnola
are unreliable and of no consequence. Spears will not be
relieved of the negligence additions to tax based on the
preliminary reports prepared by Carmagnola.
Spears also placed into the record of his case several
documents, ostensibly submitted as evidence that he monitored his
investments in the Plastics Recycling transactions. These
included unaudited, unreviewed financial statements of SAB
Leasing Associates for 1982, a 1982 update regarding placement of
the recyclers, financial statements of SAB Associates for 1979
and 1980, and introductory information regarding SAB Leasing
Associates. Spears did not testify or otherwise indicate that he
ever examined these documents. At trial, Spears could not recall
having received and read a confidential memorandum, addressed to
all limited partners, that discussed SAB Associates' change of
business from tax straddle investments to leasing plastics
recyclers. Spears could not recall the conversations he had with
Becker; he did not know how many SAB recycling partnerships
Becker was involved in; and he did not know whether there was an
established market for the Sentinel EPE recyclers. The offering
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