- 14 - not personally investigate the value or uniqueness of the Sentinel EPE recycler. Petitioner did not believe he was qualified to do so and "wouldn't know where to start." He did not retain an independent plastics recycling expert to conduct such an investigation. Petitioner did not learn whether Marcus had any expertise or experience in plastics materials or plastics recycling; or how Marcus became aware of the Plastics Recycling transactions; or what Marcus did, if anything, to investigate Resource or the Plastics Recycling transactions; or whether Marcus received a commission as a result of petitioner's investment. Petitioner never made a profit from his investment in Resource. Neither Marcus, Hefter, nor petitioner's wife Robin testified at the trial of this case. OPINION We have decided a large number of the Plastics Recycling group of cases. Provizer v. Commissioner, T.C. Memo. 1992-177, concerned the substance of the partnership transaction and also the additions to tax. See also Kaliban v. Commissioner, T.C. Memo. 1997-271; Sann v. Commissioner, T.C. Memo. 1997-259, and cases cited therein. The majority of these cases, like the present case, raised issues regarding additions to tax for negligence and valuation overstatement. We have found thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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