- 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 cashPage: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
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