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values of the Sentinel EPE recyclers that generated the
deductions and credits in these cases. Yet the purported value
of the Sentinel EPE recyclers is the very thing that petitioners
and Gallagher did not verify. A taxpayer may rely upon his
adviser's expertise (in these cases financial planning 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. Patin v.
Commissioner, 88 T.C. 1086 (1987); Lax v. Commissioner, T.C.
Memo. 1994-329.
In fact, both Black and Bennett plainly were more capable of
assessing the economic value of the recyclers than Gallagher
because of their experience pricing machinery at Ingersoll-Rand.
Petitioners also had ready access to the IMCO subsidiary of
Ingersoll-Rand, which was involved in plastics and possibly used
the same type of pellets produced by the Sentinel EPE recycler.
Petitioners had a list of supposed end-users of the recycler and
an open invitation from Gallagher to arrange for a tour to see
the equipment in operation. Even though petitioners could have
independently investigated the recyclers, they did nothing more
than have Gallagher verify the existence of the recyclers.
Petitioners expected no more from Gallagher, for as Bennett
testified, he could not assess the machines from a technical
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