- 28 - Commissioner, 91 T.C. 396, 423-424 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Pritchett v. Commissioner, 63 T.C. 149, 174-175 (1974). 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. The record does not show that Efron possessed any special qualifications or professional skills in the recycling or plastics industries. In addition, Efron did not hire anyone with plastics or recycling expertise to evaluate the Clearwater transaction. Petitioner testified that in 1981 he consulted with the following individuals concerning investments: (1) Jeffrey Jacobs, his attorney and agent; (2) Artie Brown, his accountant; and (3) "other people * * * [who] came out of the woodwork and offered [him] investments." Efron was not petitioner's agent or attorney in 1981. Petitioner met Efron through one of petitioner's teammates at a cocktail party. Prior to petitioner's investment in EI, he and Efron had only an acquaintance which petitioner described as a "friendship type" of relationship. Although he had met Efron a few times before investing in EI, he had not used Efron as anPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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