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would reasonably lead them to believe that the Plastics Recycling
transactions would be economically profitable. Becker relied
heavily upon representations by insiders to the Plastics
Recycling transactions, and neither he nor petitioners hired any
independent experts in the field of plastic materials or plastics
recycling. Becker did discuss the transactions with Canno, who
apparently was familiar with the plastics industry, but Canno was
not hired by Becker to investigate PI and the Sentinel EPE
recycler, never saw a Sentinel EPE recycler, and never prepared
any kind of formal, written analysis of the venture. The facts
of these cases are distinctly different from those in the Mollen
case. Therefore, we consider petitioners' arguments with respect
to the Mollen case inapplicable under the circumstances of these
cases.
5. Conclusion As to Negligence
Under the circumstances of these cases, petitioners failed
to exercise due care in claiming large deductions and tax credits
with respect to the Partnerships on their respective Federal
income tax returns. Petitioners did not reasonably rely upon the
offering memoranda or the materials appended thereto. Becker did
not possess any education, special qualifications, or
professional skills in the plastics or recycling industries; he
did not employ any experts in those fields; and he disclosed to
petitioners the limits of his investigation. See Goldman v.
Commissioner, 39 F.3d at 408; Marine v. Commissioner, 92 T.C.
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