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substance of Series 162 or any other of the Barrister
partnerships.
Petitioner solely relied on the advice of the C.P.A.'s,
attorneys, and other tax professionals in determining whether to
invest in Series 162. At trial, petitioner acknowledged that
none of these individuals were knowledgeable about the book
publishing industry. The advice of these individuals appears,
from the record, to have been strictly about the tax aspects of
the venture. As stated above, this Court has rejected pleas of
reliance when neither the taxpayer nor the advisers purportedly
relied on 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. Such is the case
here. Petitioners have failed to persuade the Court that their
actions in connection with their investment in Series 162 were
reasonable in light of their experience and the nature of their
investment. Petitioner acknowledged at trial that, based on the
presentation of the promoters at the recruitment meeting in 1983,
he was not satisfied about the merits of the promotion and was
skeptical that the Barrister partnerships had economic substance.
Petitioner was not only an investor, but he was also a promoter
of investments in the partnerships from which he derived
substantial sales commissions. He made no independent
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