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their education and professional experiences, petitioners should
have recognized it as well. Friedman acknowledged that he
recognized the nature of the tax benefits, and undoubtedly they
were made clear to Alter by Feinstein. Yet, neither Friedman,
Alter, nor their colleagues at Shea & Gould confirmed the value
of the Sentinel EPE recycler. The records in these cases show
that in the end, petitioners and their colleagues 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."
Neither Feinstein nor the participating partners at Shea &
Gould had any expertise in plastics materials or plastics
recycling. Although Ferraro apparently worked many years ago for
one or more summers at a plastics company, and Carroll had an
engineering background, they did not testify in these cases, and
the records fail to establish that Ferraro's summer job
experience, or Carroll's engineering background, adequately
enabled them to assess the Plastics Recycling transactions. A
taxpayer may rely upon his advisers' expertise, 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 that
he does not verify. See David v. Commissioner, 43 F.3d at 789-
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