Daniel C. Greer and Winnie L. Greer - Page 18

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         Commissioner, 60 T.C. 728, 740 (1973).  The taxpayer’s reliance              
         upon a qualified adviser is also a factor, and the specific                  
         expertise of the adviser is considered.  Patin v. Commissioner, 88           
         T.C. 1086, 1130-1131 (1987), affd. sub nom. Hatheway v.                      
         Commissioner, 856 F.2d 186 (4th Cir. 1988), affd. sub nom. Skeen             
         v. Commissioner, 864 F.2d 93 (9th Cir. 1989), affd. without                  
         published opinion 865 F.2d 1264 (5th Cir. 1989), affd. sub nom.              
         Gomberg v.  Commissioner, 868 F.2d. 865 (6th Cir. 1989).                     
              Mr. Greer had no prior experience in the recycling business.            
         He relied upon the purported value of the Sentinal EPS Recyclers             
         set forth in the offering memorandum.  He made no attempt to                 
         verify the value of the recyclers.  Given the nature of the tax              
         benefits claimed, this omission supports respondent’s assertion of           
         negligence.  Rybak v. Commissioner, 91 T.C. 524, 565 (1988).  Mr.            
         Greer contacted his longstanding tax accountant, and the                     
         accountant warned Mr. Greer that the transaction was fairly                  
         aggressive.  Rather than seek a written opinion from his                     
         accountant on the validity of the tax benefits, Mr. Greer relied             
         upon HG, the investment brokerage firm that brought him the                  
         transaction.  Obviously, the brokerage firm received a commission.           
         In addition, the individuals at HG who sold the Madison                      
         transaction to Mr. Greer did not have specialized tax expertise.             
              Mr. Greer asserts that HG came recommended by his employer.             
         Regardless, Mr. Greer’s business experience prior to 1982 was such           

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