Charles A. Greene and Christine J. Greene - Page 21

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          See, e.g., Illes v. Commissioner, 982 F.2d 163, 166 (6th Cir.               
          1992), affg. T.C. Memo. 1991-449.                                           
               Petitioner's evidence further fails to show that Corman had            
          any expertise in the nontax, business aspects of Mid Continent,             
          or that he conferred with experts in the field.  When questioned            
          as to why he thought Corman was qualified to give oil and gas               
          investment advice, petitioner testified that Corman "served on              
          committees and various programs for different parties for                   
          investment purposes", such as "B'nai Brith in Greensboro, a                 
          couple of corporations, fabric corporations in Greensboro, and a            
          couple furniture companies in High Point."  Petitioner admitted             
          that Corman's only knowledge about the oil and gas industry came            
          from reading partnership investment prospectuses.                           
               Petitioners cite United States v. Boyle, 469 U.S. 241, 251             
          (1985), for the proposition that taxpayers are entitled to rely             
          on "expert accountants and attorneys for substantive tax advice".           
          What petitioners are attempting to do, however, is to justify               
          relying on the alleged advice of an accountant about an oil and             
          gas investment, a matter in which he had no expertise.  We recall           
          petitioner's testimony that when he started his furniture                   
          manufacturing business, he did not rely solely on the advice of             
          his friend Corman (who by petitioner's own description had                  
          extensive accounting experience in the furniture business).                 
          Petitioner, in addition, sought advice from those familiar with             

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