- 37 - 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 engagingPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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