- 34 -
reasonably relied upon the offering memorandum or any expert
advice. Accordingly, we consider petitioners' reliance on the
Mollen, Brifman, Gralnek, and Butler cases misplaced.
6. Conclusion
In view of petitioner's educational background and extensive
experience in plastics and the nature and extent of his
investigation, he learned or should have learned that the
Sentinel EPE recycler was not unique and not worth in excess of
$50,000, and that Northeast lacked economic substance and had no
potential for profit. Petitioner's self-serving testimony to the
contrary is 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 v. Commissioner,
87 T.C. 74, 77 (1986); Snyder v. Commissioner, T.C. Memo. 1995-
285; Sacks v. Commissioner, T.C. Memo. 1994-217, affd. 82 F.3d
918 (9th Cir. 1996). In contrast, the reports of respondent's
experts Lindstrom and Grossman, which reach opposite conclusions
from petitioner's, are reasonable and persuasive, and the
testimony of these experts is supported by other portions of the
record. See Gottsegen v. Commissioner, T.C. Memo. 1997-314;
Provizer v. Commissioner, T.C. Memo. 1992-177.
Under the circumstances of this case, petitioners failed to
exercise due care in claiming a large loss deduction and tax
credits with respect to Northeast on their Federal income tax
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