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materials clearly stated that there was no established market for
the recyclers. We decline to infer from these documents or the
balance of the record that Spears actively monitored his
investments in the Plastics Recycling transactions.
Petitioners' reliance on Mollen v. United States, 72 AFTR 2d
93-6443, 93-2 USTC par. 50,585 (D. Ariz. 1993) is misplaced. The
taxpayer in Mollen was a medical doctor who specialized in
diabetes and who, on behalf of the Arizona Medical Association,
led a continuing medical education (CME) accreditation program
for local hospitals. The underlying tax matter involved the
taxpayer's investment in Diabetics CME Group, Ltd., a limited
partnership that invested in the production, marketing and
distribution of medical educational video tapes. District Court
found that the taxpayer's personal expertise and insight in the
underlying investment gave him reason to believe it would be
economically profitable. Although the taxpayer was not
experienced in business or tax matters, he did consult with an
accountant and a tax lawyer regarding those matters. Moreover,
the District Court noted that the propriety of the taxpayer's
disallowed deduction therein was "reasonably debatable." Id.;
see Zfass v. Commissioner, T.C. Memo. 1996-167.
The records in these cases show that neither petitioners nor
Becker had any formal education, expertise, or experience in
plastics materials or plastics recycling. None of them had any
personal insight or industry know-how in plastics recycling that
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