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contact or consult with anyone who possessed such qualifications.
Given Stewart's background and experience, he undoubtedly was
aware that the tax benefits outlined in the offering memorandum
and claimed by petitioners depended in large part on the value of
the recycling machines. Nevertheless, having no knowledge or
background regarding the value of the recyclers, he did nothing
sufficient to verify the representations made in the promotional
materials and by individuals associated with the promotion. As
we view the matter, Stewart's trip to inspect the recyclers was
essentially superficial. In effect, he relied not upon the
information he gathered through his own investigation, but upon
representations made by Southeast's promotional materials and
promoters.
Taking the above into consideration, the Gilmores', Wilson's
and G&W's (through Gilmore and Wilson) reliance upon Stewart was
not reasonable. A taxpayer may rely upon his adviser's
expertise, in this case financial planning and tax advice, but it
is not reasonable to rely upon an adviser regarding matters
outside his field of expertise or with respect to facts which he
does not verify, in this case the value of the recycler. Skeen
v. Commissioner, 864 F.2d 93 (9th Cir. 1989), affg. Patin v.
Commissioner, 88 T.C. 1086 (1987).
Moreover, Stewart was not an independent adviser since he
was entitled to receive compensation from Southeast for the
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