- 39 -                                         
          We disagree.  See Barlow v. Commissioner, T.C. Memo. 2000-339;              
          cf. Dyckman v. Commissioner, T.C. Memo. 1999-79; Zidanich v.                
          Commissioner, T.C. Memo. 1995-382.  Petitioner was sufficiently             
          experienced and sophisticated to know that SAB Foam was a tax               
          shelter, and that the value of the transaction depended on the              
          value of the underlying assets; and he failed to consult either             
          an independent appraiser or anyone with expertise in plastics               
          recycling.                                                                  
               In addition, the evidence does not support petitioner’s                
          claims that he had a unique and special relationship with his               
          advisers Miller and Becker.  Cf. Dyckman v. Commissioner, supra             
          (absolving taxpayers from the negligence penalty, in part,                  
          because of the long-term special relationship of trust and                  
          friendship between the taxpayers and their adviser).                        
               First, petitioner contends that he “kept in touch” with                
          Miller over the 10 years after he left Miller & Summit.  At                 
          trial, however, Miller testified that after petitioner left the             
          firm, they “rarely” kept in touch.  On this matter, we consider             
          Miller a more reliable witness than petitioner.  Miller’s                   
          testimony clearly shows that he had no special and close                    
          relationship with petitioner during the years in issue.                     
          Petitioner asserts that he also had an especially close                     
          relationship with PI.  Petitioner testified, however, that he did           
          not do any work for PI after he left Miller & Summit, and that              
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