- 20 - 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 reviewPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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