- 40 - T.C. 1086, 1131 (1987), affd. without published opinion 865 F.2d 1264 (5th Cir. 1989), affd. without published opinion sub nom. Hatheway v. Commissioner, 856 F.2d 186 (4th Cir. 1988), affd. sub nom. Skeen v. Commissioner, 864 F.2d 93 (9th Cir. 1989), affd. sub nom. Gomberg v. Commissioner, 868 F.2d 865 (6th Cir. 1989), sustaining negligence determinations despite claims by taxpayers that they relied on advisers, where such advisers lacked relevant expertise or knowledge of underlying transactions. Feinstein claimed that he came to a positive conclusion with respect to the soundness of the Plastics Recycling transactions, and that he communicated this conclusion to Alter. However, Feinstein did not personally invest in a Plastics Recycling transaction; nor did his friend Lauren. In the end, Alter and Feinstein relied on the offering materials and representations by insiders for the value of the machines and the economic viability of the Plastics Recycling transactions. See Vojticek v. Commissioner, T.C. Memo. 1995-444, to the effect that advice from such persons "is better classified as sales promotion." We hold that petitioners' purported reliance on Alter and Feinstein was not reasonable, not in good faith, nor based upon full disclosure. Petitioners' testimony in these cases was self- serving and in significant respects not credible, and this Court is not required to accept it as true. Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992); TokarskiPage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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