- 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); Tokarski
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