Stuart A. and Harriet J. Gollin, et al. - Page 63

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          the production, marketing, and distribution of medical                      
          educational video tapes.  The District Court found that the                 
          taxpayer's personal expertise and insight in the underlying                 
          investment gave him reason to believe it would be economically              
          profitable.  Although the taxpayer was not experienced in                   
          business or tax matters, he did consult with an accountant and a            
          tax lawyer regarding those matters.  Moreover, the District Court           
          noted that the propriety of the taxpayer's disallowed deduction             
          therein was "reasonably debatable."  Id. at 93-6447, 93-2 USTC              
          par. 50,585, at 89,895; see Zfass v. Commissioner, T.C. Memo.               
          1996-167.                                                                   
               Neither petitioners nor Becker had any formal education,               
          expertise, or experience in plastics recycling.  Neither Cohen,             
          Steele, nor Hertan ever represented that he was expert in                   
          plastics recycling and Fredericks and Fishbach had no reason to             
          believe otherwise.  The records indicate that none of petitioners           
          or their purported advisers had any personal insight or industry            
          know-how in plastics recycling that would reasonably lead them to           
          believe that the Plastics Recycling transactions would be                   
          economically profitable.  Although Fredericks served on the board           
          of a plastics molding company, there is no showing in docket No.            
          21847-90 that this gave him special insight into plastics                   
          recycling.  Moreover, when he purportedly spoke to Porter about a           
          polyethylene or polystyrene recycler, he sought no advice                   






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