Ira S. Greene and Robin C. Greene - Page 14

                                       - 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 the                  









Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011