- 22 - We hold that petitioners' failure to look beyond the Northeast offering memorandum and the representations by two insiders of Northeast was unreasonable and not in keeping with the standard of the ordinarily prudent person. See LaVerne v. Commissioner, 94 T.C. 637 (1990); Marine v. Commissioner, 92 T.C. 958 (1989). We find no merit in petitioners' argument about their supposed faith in the representations in the offering memorandum allegedly based on the concept that Federal and State securities laws discourage false and misleading statements. Petitioners' educational backgrounds and professional experience belie such feigned naivety. Likewise, since petitioners were experienced attorneys familiar with offering memoranda, we are unconvinced by their contention that they reasonably disregarded the cautionary language and risk alerts because they believed such admonitions were inserted for the benefit of the promoter. On its face, the cautionary language is directed to the investor. Petitioners have presented no reason for us to doubt that the cautionary language means what it says. Petitioners' reliance on Heasley v. Commissioner, 902 F.2d 380 (5th Cir. 1990), revg. T.C. Memo. 1988-408, and Ewing v. Commissioner, 91 T.C. 396 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991), is misplaced. The facts in the Heasley case are distinctly different from the facts of these cases. In the Heasley case, the taxpayers were not educated beyond high school and had limited investment experience, whilePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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