- 92 -                                                  
            and to stand to gain financially from the sale of both the                                 
            subject VEBA’s and the C-group product.  Given the magnitude of                            
            petitioners’ dollar investment in the C-group product and the                              
            favorable consequences which Mr. Cohen represented flowed                                  
            therefrom, any prudent taxpayer, especially one who is as                                  
            educated as the physicians at bar, would have asked a tax                                  
            professional to opine on the tax consequences of the C-group                               
            product.  The represented tax benefits of the C-group product                              
            were simply too good to be true.  Such is especially so when we                            
            consider the fact that the physicians who testified admitted that                          
            they knew that term insurance was significantly less expensive                             
            than the premiums purportedly paid under the C-group product                               
            solely for term insurance.                                                                 
                  Petitioners assert on brief that they also relied on tax                             
            opinion letters written by tax attorneys and accountants.  We do                           
            not find that such was the case.  The record contains neither a                            
            credible statement by one or more of the individual petitioners                            
            to the effect that he or she saw and relied on a tax opinion                               
            letter, nor a tax opinion letter written by a competent,                                   
            independent tax professional.  In fact, petitioners have not even                          
            proposed a finding of fact that would support a finding that such                          
            a tax opinion letter exists, let alone that any of them ever read                          
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