- 21 -
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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