Leon M. and Mary K. Jaroff - Page 51

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          Wood, a group of consolidated cases, all of the taxpayers had               
          profit objectives, the transactions were not sham transactions,             
          and one pair of taxpayers inspected the equipment at issue.  In             
          the Davis case, the taxpayers reasonably relied upon a "trusted             
          and long-term adviser" who was independent of the investment                
          venture, and the offering materials reviewed by the taxpayers did           
          not reflect that the principals in the venture lacked experience            
          in the pertinent line of business.                                          
               Unlike the taxpayer in Wright, as a former business reporter           
          for Time, petitioner plainly had the experience and education               
          necessary to recognize the importance or meaning of the warning             
          signs inherent in the Partnership transactions.  In contrast to             
          the Wood case, the Partnership transactions are shams lacking               
          economic substance; we are not convinced that petitioner had an             
          honest objective of making an economic profit; and he did not               
          inspect the recyclers.  Unlike the circumstances of the Davis               
          case, Tucker and Becker were not long-term advisers of                      
          petitioner; Becker was not independent of the SAB Recycling                 
          Partnerships; and the offering memoranda warned that the general            
          partner had no prior experience in marketing recycling or similar           
          equipment.  Accordingly, petitioners' reliance on the Wright,               
          Wood, and Davis cases is misplaced.                                         
               In Mollen v. United States, supra, the taxpayer was a                  
          medical doctor who specialized in diabetes and who, on behalf of            
          the Arizona Medical Association, led a continuing medical                   




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