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concerned petitioner Pace was whether the plant and recyclers
actually existed. He had recently read about some executives of
"Wall Street companies" who had invested in an oil and gas
venture which turned out to be nothing more than wooden pipes
painted different colors, and he did not want to blunder into an
investment in a nonexistent physical plant. Greenstein's
facilities tour verified the existence of the plant and
recyclers. With the existence of PI and the recyclers confirmed,
petitioner Pace thought he had no reason to believe Hyannis was
not a "bona fide deal" and went forth with the investment.
Petitioners' alleged reliance on Greenstein does not satisfy
the requirement that it be reasonable, in good faith, and based
upon full disclosure. The purported values of the Sentinel EPE
recyclers generated the deductions and credits in these cases.
Yet the purported value of the Sentinel EPE recyclers is the very
thing that petitioners and Greenstein did not verify. A taxpayer
may rely upon his adviser's expertise (in these cases accounting
and tax advice), but it is not reasonable or prudent to rely upon
an adviser regarding matters outside of his field of expertise or
with respect to facts which he does not verify. See Skeen v.
Commissioner, 864 F.2d 93 (9th Cir. 1989), affg. without
published opinion Patin v. Commissioner, 88 T.C. 1086 (1987); Lax
v. Commissioner, T.C. Memo. 1994-329.
Greenstein had just 2 years' experience as a C.P.A. He was
not an engineer and had no education or work experience in
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