Robert D. and Patricia K. Kaliban, et al. - Page 40

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            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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