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purchasing his Sentinel EPS recyclers. Further, we fail to
understand how petitioner could have carefully considered a legal
opinion dated December 1, 1982, when all of the operative
transactions regarding his purchase of the Sentinel EPS recyclers
occurred on that same date.
In any event, even if petitioner did rely on either Ulanoff,
Burstein, WMDI, or Boylan & Evans in purchasing his recyclers,
that reliance would not have been reasonable. Although
petitioner is an educated individual and accomplished business
executive with extensive knowledge of, and experience in, the
plastics industry, none of petitioner's supposed advisers had any
education or work experience in plastics materials or plastics
recycling. Neither petitioner nor his advisers consulted any
independent experts to help them analyze or assess the recyclers.
Thus, we think that any reliance petitioner might have placed on
any of his supposed advisers was not reasonable.
Petitioner suggests that his personal knowledge of, and
expertise in, the plastics industry made it reasonable for him to
research, investigate, and purchase Sentinel recyclers without
seeking independent expert advice. Indeed, petitioner was more
capable of assessing the economic value of the recyclers than his
supposed advisers because of his knowledge about the plastics
industry and, in particular, his experience in pricing plastics
processing machinery. Experience and knowledge alone, however,
do not make petitioner's actions reasonable. For petitioner's
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