Bruce and Lois Zenkel, et al. - Page 37

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          the Krause case, there is no showing in these records that the              
          so-called oil crisis would provide a reasonable basis for                   
          petitioners' investing in the polyethylene recyclers here in                
          question.  As noted above, petitioners did not independently                
          investigate the Sentinel EPE recyclers or hire an expert in                 
          plastics to evaluate the Partnership transactions.  The facts of            
          petitioners' cases are distinctly different from the Rousseau               
          case.  Accordingly, we do not consider petitioners' arguments               
          with respect to the Krause and Rousseau cases applicable.                   
               2.  Petitioners' Purported Reliance on Tax Advisers                    
               Petitioners also maintain that they reasonably relied upon             
          the advice of a qualified adviser.  The Zenkels discussed the               
          investment with Steele and Becker; Blount discussed it with                 
          Sprague; and the Davids and the Selvins discussed it with Becker.           
               The concept of negligence and the argument of reliance on an           
          expert are highly fact intensive.  Petitioners in these cases are           
          very well educated professionals whose intellect and business               
          sophistication are reflected in their financial and business                
          success.  Blount is a C.P.A. and business executive with 13 years           
          of accounting experience with Arthur Andersen, 3 of those as a              
          partner, and employment with American Home Products, a major                
          pharmaceutical company, initially as vice president of finance              
          and treasurer in 1974, and subsequently in positions of greater             
          responsibility.  David was a corporate attorney before engaging             






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