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employed tax return preparer, and there is no showing in the
record that he expressly recommended Plymouth to them.
Petitioners did not read the offering memorandum, see a Sentinel
EPE recycler, or make any effort to learn about the Plymouth
transactions. In addition, the Plymouth transaction is a sham
lacking economic substance, and we are not convinced that
petitioners had an honest objective of making a profit.
Accordingly, we consider the Wright, Daoust, Wood, and Davis
cases distinguishable from the instant case.
In Mollen v. United States, supra, the taxpayer was a
medical doctor who specialized in diabetes and who, on behalf of
the Arizona Medical Association, led a continuing medical
education (CME) accreditation program for local hospitals. The
underlying tax matter involved the taxpayer's investment in
Diabetics CME Group, Ltd., a limited partnership which invested
in the production, marketing, and distribution of medical
educational video tapes. The District Court found that the
taxpayer's personal expertise and insight in the underlying
investment gave him reason to believe it would be economically
profitable. Although the taxpayer was not experienced in
business or tax matters, he did 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." See Zfass v. Commissioner,
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