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In addition, the taxpayers in the Krause case were
experienced in or investigated the oil industry and EOR
technology specifically. One of the taxpayers in Krause v.
Commissioner, supra, undertook significant investigation of the
proposed investment including researching EOR technology. The
other taxpayer was a geological and mining engineer whose work
included research of oil recovery methods and who hired an
independent geologic engineer to review the offering materials.
Id. at 166. In the present cases, petitioners were not
experienced or educated in plastics recycling. Petitioner did
not independently investigate the Sentinel recyclers or hire an
expert in plastics to evaluate the Partnership transactions. We
consider petitioners' arguments with respect to the Krause case
inapplicable.
3. Petitioners' Purported Reliance on a Tax Adviser
Petitioner maintains that he reasonably relied upon the
advice of a qualified adviser, Tucker, and that he relied on
various representations allegedly made by Tucker about what
Becker had done.
The concept of negligence and the argument of reliance on an
expert are highly fact intensive. Petitioner is well educated;
he earned degrees in electrical engineering and mathematics from
the University of Michigan. For approximately 30 years, he
worked variously as a reporter, bureau correspondent, editor,
senior editor, and managing editor for Life magazine, Time
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