- 14 - (1990), affd. without published opinion 956 F.2d 274 (9th Cir. 1992), affd. without published opinion sub nom. Cowles v. Commissioner, 949 F.2d 401 (10th Cir. 1991); Marine v. Commissioner, 92 T.C. 958, 992-993 (1989), affd. without 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 first learned of the Northeast transaction from Grant. Grant and petitioner worked in the same accounting firm for 2 years in the late 1940's, and they were members of the same tennis and social club during the late 1970's. Petitioner explained that "The Shelter Rock Tennis Club was a country club based on tennis. It had a restaurant and a bar, and it was a social center for its members." Petitioner stated that he and Grant played tennis together and shared social acquaintances, and that Grant "lived quite well, somewhat expensively." Petitioner also noted that he and Grant's brother-in-law had been partners in the same accounting firm. Petitioner was aware that Grant had no background knowledge or expertise in the plastics recycling area.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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