Bruce and Lois Zenkel, et al. - Page 47

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          and leave it open for them to define what I might or might not              
          have done."                                                                 
               The purported value of the Sentinel EPE recycler generated             
          the deductions and credits in these cases, and that circumstance            
          was reflected in the offering memoranda.  Certainly Becker                  
          recognized the nature of the tax benefits and, given their                  
          education and business experience, petitioners should have                  
          recognized it as well.  Yet neither petitioners nor Becker                  
          verified the purported value of the Sentinel EPE recycler.                  
          Becker confirmed at trial that he relied on PI for the value of             
          the Sentinel EPE recyclers.  Investors as sophisticated as                  
          petitioners either learned or should have learned the source and            
          shortcomings of Becker's valuation information when he reported             
          to them and "precisely" disclosed "what [he] had done to                    
          investigate or analyze the transaction."  Accordingly, we hold              
          that petitioners did not reasonably or in good faith rely on                
          Becker as an expert or a qualified professional working in the              
          area of his expertise to establish the fair market value of the             
          Sentinel EPE recycler and the economic viability of the                     
          Partnership transactions.  Becker never assumed such                        
          responsibility, and he fully described the particulars of his               
          investigation, taking care not to mischaracterize it as "due                
          diligence."                                                                 








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