- 26 - the full extent of his investigation, such as his visit to PI, speaking with Canno, and his research of trade journals to confirm the price of plastic pellets. Becker never represented that he was an expert in plastics materials or plastics recycling. Selvin did not do any independent investigation of the Sentinel EPE recyclers or plastics recycling in general. He invested in Scarborough based solely on his review of the offering materials and his discussions with Becker. After the 1981 SAB Recycling Partnerships closed, Becker paid Selvin's accounting firm to send an accountant to PI to confirm, by serial number, that as of December 31, 1981, the equipment that was leased to the 1981 SAB Recycling Partnerships was indeed available for use. Becker arranged for this verification, independent of PI, because he understood that the investment tax and business energy credits would not be available if the qualifying property was not available for use. OPINION We have decided more than 30 of the Plastics Recycling group of cases.2 The majority of these cases, like the consolidated 2 Provizer v. Commissioner, T.C. Memo. 1992-177, affd. without published opinion 996 F.2d 1216 (6th Cir. 1993), concerned the substance of the partnership transaction and also the additions to tax. The following cases concerned the addition to tax for negligence, inter alia: Estate of Busch v. Commissioner, T.C. Memo. 1996-342; Spears v. Commissioner, T.C. Memo. 1996-341; Stone v. Commissioner, T.C. Memo. 1996-230; Reimann v. (continued...)Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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