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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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