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Commissioner, 949 F.2d 401 (10th Cir. 1991); Marine v.
Commissioner, 92 T.C. 958, 992-993 (1989), affd. without
published opinion 921 F.2d 280 (9th Cir. 1991); McCrary v.
Commissioner, 92 T.C. 827, 850 (1989); Rybak v. Commissioner, 91
T.C. 524, 565 (1988). We have rejected pleas of reliance when
neither the taxpayer nor the advisers purportedly relied upon by
the taxpayer knew anything about the nontax business aspects of
the contemplated venture. Beck v. Commissioner, 85 T.C. 557
(1985); Flowers v. Commissioner, 80 T.C. 914 (1983); Steerman v.
Commissioner, T.C. Memo. 1993-447.
Based upon our review of the entire records in these cases,
we hold that Stone's purported reliance on Tomasetti, and Cote's
purported reliance on Frabotta and Omohundro, and through them
Tomasetti, was not reasonable, not in good faith, nor based upon
full disclosure. Neither petitioners, nor their supposed
advisers, nor anyone affiliated with them had any education or
work experience in plastics materials or plastics recycling.
Neither petitioners nor their supposed advisers consulted any
independent experts or conducted anything approaching a
meaningful investigation. In addition, it is clear that
Tomasetti had serious concerns regarding the recycler's purported
value, and nothing in the records indicates that his concerns
were not communicated to petitioners.
Frabotta's purported investigation entailed speaking to a
client contact at Global Marine about the price of oil, a review
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