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Commissioner, 85 T.C. 557 (1985).
In the present cases, Kabeck read the offering memorandum.
However, Kabeck had no specialized knowledge or experience in
plastics materials or plastics recycling and no specialized
knowledge in valuing plastics recycling machines such as the
Sentinel EPS recycler. In view of Kabeck’s lack of knowledge
regarding either the nontax or business aspects of the Dickinson
investment, petitioner’s alleged reliance on his accountant does
not relieve petitioner of liability for the additions to tax for
negligence. See Addington v. Commissioner, 205 F.3d 54 (2d Cir.
2000).
Petitioner also contends that he reasonably relied on his
medical colleagues, particularly Krickstein. However, petitioner
did not have any specific conversations with his colleagues about
either Dickinson or plastics recycling before making the
investment. Indeed, petitioner did not even think that his
medical colleagues had any specialized knowledge in plastics
recycling or in plastics recycling machines such as the Sentinel
EPS recycler.14 See Addington v. Commissioner, supra. Rather,
petitioner merely assumed that Krickstein and other medical
colleagues were investing in Dickinson. In short, the perception
that his colleagues were investing made petitioner want to
14 It would appear that any knowledge that Krickstein may
have had about the Dickinson transactions came from Gordon. See
Vojticek v. Commissioner, T.C. Memo. 1995-444.
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