- 66 -
consult with an accountant and a tax lawyer regarding those
matters. Moreover, the District Court noted that the propriety
of the taxpayer's disallowed deduction therein was "reasonably
debatable." Id. at 93-6447, 93-2 USTC par. 50,585, at 89,895;
see Zfass v. Commissioner, T.C. Memo. 1996-167.
In contrast, petitioners in these cases did not have any
personal insight or industry know-how in plastics recycling that
would reasonably lead them to believe that the Plastics Recycling
transactions would be economically profitable. Although Sann
spoke to client contacts in the oil business about the price of
oil, he understood that they could only speculate about the
direction of the price of oil. Moreover, petitioners' purported
adviser, Maxfield, advised the members of Sann & Howe that the
relationship between the price of the recycled pellets and the
price of oil was a negative aspect of the investment.
Petitioners and Maxfield relied upon the offering materials and
persons with an interest in the Plastics Recycling transactions.
Accordingly, we consider petitioners' arguments with respect to
the Mollen case inapplicable under the circumstances of these
cases.
Petitioners' arguments are not supported by Anderson v.
Commissioner, supra, where the taxpayers were found liable for
the negligence additions to tax. In Anderson, the taxpayers
claimed tax benefits based upon their acquisition of property
listed at $124,500, for which they actually paid $6,225 in a cash
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