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Commissioner, 92 T.C. 827, 850 (1989); Rybak v. Commissioner, 91
T.C. 524, 565 (1988). We have rejected pleas of reliance when
neither the taxpayer nor the advisers purportedly relied upon by
the taxpayer knew anything about the nontax business aspects of
the contemplated venture. Beck v. Commissioner, 85 T.C. 557
(1985); Flowers v. Commissioner, 80 T.C. 914 (1983); Steerman v.
Commissioner, T.C. Memo. 1993-447.
These cases do not present a situation such as that found in
Heasley v. Commissioner, 902 F.2d 380, 385 (5th Cir. 1990), revg.
T.C. Memo. 1988-408, where the Fifth Circuit Court of Appeals
held that taxpayers, who were unsophisticated investors not
educated beyond high school, were not liable for the negligence
additions to tax. The facts in the present cases are
distinguishable. Petitioners herein are all well-educated. The
late Edgar Berry was a surgeon in 1981 and his wife, petitioner
Dorothy Berry, graduated from Radcliffe College. Petitioner Pace
graduated from St. Bonaventure in 1958. He has been working in
the brokerage business since the late 1960's and during 1981 he
was a highly compensated institutional salesman at Bear Stearns &
Co. Petitioners Pace reported income or losses from nine
different partnerships on their 1981 Federal income tax return,
while petitioners Berry reported income or losses from four
different partnerships, estates or trusts, or small business
corporations. Accordingly, the record indicates that unlike the
taxpayers in Heasley, petitioners in these cases were not
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