Leon M. and Mary K. Jaroff - Page 52

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          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 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.                                                                   
               Petitioner and Becker have no formal education, expertise,             
          or experience in plastics recycling.  Tucker never represented              
          that he was expert in plastics recycling, and petitioner had no             
          reason to believe otherwise.  There is no showing in the record             
          that petitioner, Tucker, or Becker 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.  Becker purportedly discussed             
          the transactions with Canno, who apparently was familiar with the           
          plastics industry, but Canno was not hired by Becker to                     
          investigate PI and the Sentinel EPE recycler, never saw a                   




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