- 18 - Should you elect to schedule more time with Mr. Shriver, he will discuss a fee schedule for the services to be rendered. Petitioner entered into a $1,500 agreement with Professional for service, which included 1 hour with a "certified public accountant", whom we must assume is Mr. Shriver. Petitioner has failed to show Mr. Shriver's independence from the organization that, at the very least, benefits from the sale of the investment opportunity on which Mr. Shriver opined. Considering established precedent and the specific circumstances of this case, it was not reasonable for petitioner to rely on the individuals in question. Petitioner had a clear basic understanding of the dynamics and magnitude of this energy-device transaction. He was aware that his tax benefits and any potential for income stemmed from the lease of a device whose purported cost, relative to his net worth and income, was substantial. His focus was primarily, if not solely on the tax benefits. Petitioner would have otherwise been concerned about the bona fides of the transaction. If petitioner was interested in income (retirement or otherwise) he would, at the very least, want to know whether such an energy device existed, operated, was leased and had value equivalent to the claims on which his reported credits and deductions were based. Accordingly, it was not reasonable for him to ignore the bona fides of the transaction or to rely on persons who were without specialized knowledge or who had a financial interest inPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011