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knew or should have known to exercise caution in relying upon the
seller’s representative for advice as to whether they should buy.
On this record, we hold that it was not reasonable for
petitioners to claim substantial tax credits and partnership
losses on the basis of Mejia’s, Grande’s, or Maki’s advice.
Neither Grande nor Maki had the requisite expertise or knowledge
of the pertinent facts to provide informed advice regarding the
claimed partnership losses and tax credits. A taxpayer may rely
upon his adviser’s expertise, but it is not reasonable or prudent
to rely upon an adviser regarding matters outside of his field of
expertise or with respect to facts that he does not verify. See
David v. Commissioner, supra at 789-790; Goldman v. Commissioner,
39 F.3d 402, 408 (2d Cir. 1994); Freytag v. Commissioner, 89 T.C.
849 (1991); Sann v. Commissioner, supra. Moreover, as indicated
above, in these cases there is no credible evidence that either
of them offered advice beyond his limited area of knowledge
relating to the technical tax aspects of the transaction.
Petitioners’ purported reliance on Mejia’s advice was also
unreasonable. We have consistently held that advice from such
persons is better classified as sales promotion. See Singer v.
Commissioner, T.C. Memo. 1997-325; Sann v. Commissioner, supra;
Vojticek v. Commissioner, T.C. Memo. 1995-444. We note that in
these cases, Mejia did not testify, and that circumstance
suggests that if he had testified, that testimony would have been
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