- 25 - angle design of the EPE recyclers and the purportedly unique chemical process used to recycle the material) and warranted the $1,162,667 price tag. Although petitioner may have been more familiar with chemical processes because of his college degree--or with machine designs because of his limited patent law experience–-than the average investor, it is clear that he did not have adequate plastics industry knowledge to evaluate the investment. See Addington v. Commissioner, supra. Petitioner did not have any expertise in plastics recycling or evaluation of machinery, including plastics recycling equipment, to evaluate competently the profitability of the Clearwater transaction. We have found that the EPE recyclers did not have a fair market value of more than $50,000 and that the recyclers did not have any unique features warranting their exorbitant pricetag. By simply relying on petitioner’s limited knowledge and experience, without independent research or consultation, petitioners never made an adequate effort to learn that the EPE recyclers were highly overvalued or the true nature of the transaction as a sham. There is also no indication that petitioners invested the necessary time to gain the requisite expertise to evaluate their investment. Petitioners claim that petitioner discussed the investment with several partners in his firm, the majority ofPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011