- 13 - published opinion 921 F.2d 280 (9th Cir. 1991); McCrary v. Commissioner, 92 T.C. 827, 850 (1989); Rybak v. Commissioner, 91 T.C. 524, 565 (1988). We have rejected pleas of reliance when neither the taxpayer nor the advisers purportedly relied upon by the taxpayer knew anything about the nontax business aspects of the contemplated venture. Beck v. Commissioner, 85 T.C. 557 (1985); Flowers v. Commissioner, 80 T.C. 914 (1983); Steerman v. Commissioner, T.C. Memo. 1993-447. Petitioner's investigation of the Hyannis transaction did not extend beyond discussions with Miller and Roberts and a review of the offering memorandum. Petitioner had met Miller, and Miller had urged him to consider Roberts' proposals. Petitioner had taken no action on several deals proposed by Roberts, but the plastics recycling idea interested him. Moreover, petitioner testified that because he knew Miller personally and had a lot of confidence in him, petitioner decided to look into the plastics recycling proposal. Petitioner did not explain exactly why he had any confidence in Miller. The record is devoid of any history of past dealings between petitioner and Miller on either a personal or professional basis. Nonetheless, petitioner's purported confidence in Miller is petitioner's only explanation of his reason for considering the recycling proposal and for failing to make any investigation of Roberts. Petitioner indicated some interest when Roberts called about the plastics recycling deal, and a copy of the Hyannis offering memorandum was sent to petitioner. Petitioner testified that hePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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