- 53 -- 53 -
market. On cross-examination, Fredericks summed up his
conversation with Porter as follows:
Q So, basically, all you asked [Porter] was whether
recycling was a--a feasible--a feasible thing, a feasible
process.
A As I testified, I asked him is a recycling machine a
viable economic entity.
Q Okay. But you didn't go into the specifics of this
machine.
A I did not.
We hold that Fredericks' purported reliance on Steele,
Cohen, and Porter was not reasonable, not in good faith, nor
based on full disclosure. Nothing in the record in docket No.
21847-90 suggests the nature of the advice, if any, Fredericks
received from Steele, other than the monetary impact the
investment would have on his taxes. See Patin v. Commissioner,
88 T.C. at 1131. Fredericks did not consider Cohen to be an
engineer or an expert in plastics recycling. Essentially, Cohen
told Fredericks nothing more than that he had invested in a
virtually identical tax-advantaged Plastics Recycling transaction
a year before. The two did not discuss anything of substance;
Fredericks did not even ask Cohen if he had received any royalty
distributions. Fredericks' discussion with Porter was similarly
bereft of substantive advice. The only thing Fredericks asked
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