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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
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