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financial "dummies." In contrast to those cases, petitioners
herein are well educated, sophisticated, and successful
businessmen. Becker and Green were not long-term advisers of
petitioners. Green was an investor in the oil drilling ventures,
and he recommended the appropriate legal structure for the
ventures. However, there is no showing in the records that Green
acted as a tax or investment adviser to petitioners. As for
petitioners' tax return preparers, the records fail to show their
qualifications to analyze the Partnership transactions, what they
did, and the subject of their advice, if any. In addition, the
offering memoranda disclosed that the Partnerships had no prior
operating history and that the general partner had no prior
experience in marketing recycling or similar equipment.
Petitioners' position is not supported by Mollen v. United
States, 72 AFTR 2d 93-6443, 93-2 USTC par. 50,585 (D. Ariz.
1993). In Mollen, the taxpayer was a medical doctor who
specialized in diabetes and who, on behalf of the Arizona Medical
Association, led a continuing medical education (CME)
accreditation program for local hospitals. The underlying tax
matter involved the taxpayer's investment in Diabetics CME Group,
Ltd., a limited partnership that invested in 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 every reason to
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