Philippe and Nadine Grelsamer - Page 46

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          assumed such responsibility, and he fully described the                     
          particulars of his investigation, taking care not to                        
          mischaracterize it as "due diligence."                                      
               In the end, Becker and petitioners 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."  A                  
          taxpayer may rely upon his adviser's expertise (in these cases,             
          accounting and tax advice), but it is not reasonable or prudent             
          to rely upon a tax 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 789-790; Goldman v.                   
          Commissioner, 39 F.3d at 408; 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; Sacks v.                  
          Commissioner, T.C. Memo. 1994-217; Rogers v. Commissioner, T.C.             
          Memo. 1990-619; see also Zenkel v. Commissioner, T.C. Memo. 1996-           
          398, Estate of Busch v. Commissioner, T.C. Memo. 1996-342; Spears           
          v. Commissioner, T.C. Memo. 1996-341, with respect to Becker's              
          advice in Plastics Recycling cases.                                         
               3.  The Private Offering Memoranda                                     
               In addition to purportedly relying on Becker, Green, and               
          their respective tax return preparers, petitioners maintain that            






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