Peter and Ursula Reimann, et al. - Page 30

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          recycler.  Brodie undertook no research or investigation beyond             
          speaking with Greene and "reviewing" the offering memorandum.               
          Although Greene believed his commission was disclosed to Brodie             
          by notice or letter, Brodie could not recall compensating Greene            
          for, as he put it, the "service of submitting a prospectus for me           
          to read and telling me that it was a good investment for me."               
          Greene considered the Plastics Recycling deal a tax shelter with            
          tax benefits for investors approximately four times the                     
          investment.  He obtained his information from Bachmann, and there           
          is no reason to think he did not pass on this same information to           
          his client, Brodie.                                                         
               It was petitioners' reliance upon the purported value of the           
          Sentinel EPE recycler that generated the deductions and credits             
          in these cases.  Yet the purported value of the Sentinel EPE                
          recyclers is the very thing that petitioners, and the accountants           
          Bachmann, Schwartz, did not verify.  A taxpayer may rely upon his           
          adviser's expertise (in these cases accounting, financial                   
          planning, and tax advice), but it is not reasonable or prudent              
          for petitioners to rely upon an adviser regarding matters outside           
          of his field of expertise or with respect to facts which he does            
          not verify.  See 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, affd. without published                  
          opinion 72 F.3d 123 (3d Cir. 1995).                                         
               Moreover, a careful consideration of the materials in the              
          respective offering memoranda, especially the discussions in the            



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