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upon by the taxpayer knew anything about the nontax business
aspects of the contemplated venture. David v. Commissioner,
supra; Goldman v. Commissioner, supra; Freytag v. Commissioner,
supra; Beck v. Commissioner, 85 T.C. 557 (1985); Buck v.
Commissioner, supra; Lax v. Commissioner, T.C. Memo. 1994-329,
affd. without published opinion 72 F.3d 123 (3d Cir. 1995); Sacks
v. Commissioner, supra; Steerman v. Commissioner, T.C. Memo.
1993-447; Rogers v. Commissioner, T.C. Memo. 1990-619; see also
the Plastics Recycling cases cited in Sann v. Commissioner,
supra.
Bach has no education or work experience in engineering,
plastics materials, or plastics recycling. His investigation of
the Plastics Recycling transactions and Plymouth consisted of a
review of the offering memorandum, plus a visit to the PI plant
and some end-users chosen by a PI representative. Bach
acknowledged that he does not "have a great technical background"
and that he "didn't understand the technicalities of the machine
too well even though it was explained to [him]". Because of his
limited technical background, the only question he posed to the
end-users with whom he spoke was whether the machine broke down.
Bach indicated that he deferred to Gardino with respect to
the technical aspects of the Sentinel EPE recycler. He claimed
that Gardino had a technical background, understood the
technicalities of the machine, and "asked a lot of questions
about how the machine operates, what it does." When asked if he
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