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investment adviser. The offering memorandum and the revised
offering memorandum disclosed the fact that Efron was receiving
substantial compensation and fees as the general partner of EI
and as a 50-percent owner of MFA. In addition, both of the EI
offering memoranda specifically warned potential investors that
they were "not to consider the contents of [the offering
memoranda] or any communication from the partnership or its
general partners as legal or tax advice", and Efron testified
that he advised every limited partner in EI to talk to an
independent adviser. Petitioner had such advisers available, but
testified that he did not rely upon them with respect to this
matter. In our view petitioner's reliance on Efron was not
reasonable, as Efron was merely a casual acquaintance who was
essentially selling a speculative investment product and had no
fiduciary or professional relationship with petitioner and
specifically warned him in writing to obtain independent advice.
Accordingly, we hold that petitioner is not entitled to relief
from the negligence additions to tax under section 6653(a)(1) and
(2) because of his purported reliance on Efron.
Petitioner's reliance on Heasley v. Commissioner, 902 F.2d
380 (5th Cir. 1990), revg. T.C. Memo. 1988-408, is misplaced.
The facts in the Heasley case are distinctly different from the
facts of this case. In the Heasley case the taxpayers actively
monitored their investment. Petitioner has failed to provide
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