Robert S. Cohen and Margery Cohen - Page 36

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          of PI long ago, but that in no way establishes him as an                    
          authority about PI or the plastics industry.  When Lewin was                
          employed by Miller and was assigned work for PI, that company was           
          located in New Jersey under different ownership and had not yet             
          manufactured any recyclers.  By the time of the transactions in             
          issue PI had moved to Hyannis, Massachusetts.  Nothing in the               
          record establishes that Lewin had any special knowledge about PI            
          or its business in 1981-82.  Lewin’s knowledge of SAB Foam is               
          derived primarily from the memorandum and Miller.                           
               B.  Alleged Experts                                                    
               Petitioners contend that Dooskin and Sacco provided the                
          requisite independent analysis of the investment.  We disagree.             
          Dooskin and Sacco, neither of whom had any knowledge of the                 
          plastics recycling industry, reviewed the memorandum for, at                
          most, 7 hours combined.  Their only knowledge of SAB Foam came              
          from the memorandum (i.e., promotional material).  Dooskin                  
          testified that he informed Lewin the investment “passed muster”,            
          but that the economics of the investment “was dependent upon the            
          valuation of the equipment”.  Petitioners, however, failed to               
          undertake the necessary due diligence and seek a thorough and               
          independent analysis of the value of the recyclers despite                  
          Dooskin’s warning.  We are not convinced that Dooskin’s and                 
          Sacco’s review of the memorandum was any more than a very limited           
          inquiry on behalf of Lewin.  Neither petitioner nor his partners            






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