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          advisers purportedly relied upon by the taxpayer knew anything              
          about the nontax business aspects of the contemplated venture.              
          Goldman v. Commissioner, supra; Freytag v. Commissioner, supra;             
          Beck v. Commissioner, 85 T.C. 557 (1985); Lax v. Commissioner,              
          T.C. Memo. 1994-329, affd. without published opinion 72 F.3d 123            
          (3d Cir. 1995); Steerman v. Commissioner, T.C. Memo. 1993-447;              
          Rogers v. Commissioner, T.C. Memo. 1990-619.                                
               The concept of negligence and the argument of reliance on an           
          expert is highly fact intensive.  In these cases two remarkably             
          capable and successful investment advisers, experienced and able            
          at investigating investment proposals, assert that they relied              
          upon their accountant to investigate the tax law and the                    
          underlying business circumstances of a proposed investment.  The            
          accountant explains that he made an investigation within the                
          limits of his resources and abilities and fully disclosed what he           
          had done.  The question here is whether petitioners actually and            
          reasonably relied on the accountant with respect to valuation               
          problems requiring expertise in engineering and plastics                    
          technology or whether the accountant gave the tax advice and                
          facilitated the transaction, but did not make a full and                    
          independent investigation of the relevant business and                      
          technology, and did clearly inform his clients of the limits of             
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