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warned him that the tax benefits were contingent upon the
economics of the transaction. Yet neither petitioner nor Becker
verified the purported value of the Sentinel EPE recycler.
Petitioner relied on Becker. Petitioner was well aware of
Becker's educational and professional background. Becker's
expertise was in taxation, not plastics materials or plastics
recycling, and his investigation and analysis of the Plastics
Recycling transactions reflected this circumstance. Petitioner
also spoke to his father, but there is no suggestion in the
record that petitioner's father knew anything about plastics
materials or plastics recycling, or that he advised petitioner
beyond confirming that he, too, was investing in Plastics
Recycling transactions. In the end, Becker and petitioner relied
on PI personnel for the value of the Sentinel EPE recyclers and
the economic viability of the Partnership transactions. See
Vojticek v. Commissioner, T.C. Memo. 1995-444, to the effect that
advice from such persons "is better classified as sales
promotion."
We hold that petitioner did not reasonably or in good faith
rely on Becker as an expert or a qualified professional working
in the area of his expertise to establish the fair market value
of the Sentinel EPE recycler and economic viability of the
Partnership transactions. Becker did not have any education,
special qualifications, or professional skills in plastics
materials or plastics recycling. A taxpayer may rely upon his
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